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

cnbc.com

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

#481

Post by ClassyJacket »

panzagl wrote: post #391
jandrewrogers wrote: post #366

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. 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…

If you don't like then... uh... come back?

God I hate this argument. This is such an unhelpful, useless thing to say. It doesn't provide any useful or practical suggestions, it's just a way of shutting down conversation.

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

#482

Post by qwytw »

jay_kyburz wrote: post #449
epolanski wrote: post #424

Earlier quoted context omitted.

That's not what really Apple did in Europe to pay little taxes. The scheme was essentially like this: - Apple Ireland bought iphones for 200$ or so (talking about pre X numbers, now they're likely slightly higher) - Apple Ireland sold iPhones to Apple Italy for 599€s - Apple Italy sold iPhones for 599€s + vat (thus avoiding to pay any corporate taxes in Italy while making billions) - Apple Ireland had a special agree…

A good argument for GST. With a 10% GST the Italians would have at least seen 10% of the 599.

Aren't they already getting 22% of it?

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

#483

Post by qwytw »

gunapologist99 wrote: post #421
hinkley wrote: post #362

Earlier quoted context omitted.

Maybe they should do it like Roth IRAs. You can move the money to a tax haven only after you’ve paid taxes on it. So if you’re building hotels or factories in the haven that’s fine. If you’re hiding money we demand our pound of flesh.

.. thus removing a significant portion of income from these so-called tax havens, which generally tend to be poorer countries. No one has accused Germany of being a tax haven, for instance.

> so-called tax havens, which generally tend to be poorer countries

Smaller, not poorer.

Unless you think that current or historical "tax havens" like Ireland, Luxembourg, Netherlands, Switzerland etc. were/are poorer than Germany.

If you have less than a handful of million people even getting a few percent + several thousands of jobs from corporations like Apple is a huge deal. It would be a drop in the bucket for Germany so they have no incentives to make such deals.

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

#484

Post by qwytw »

kranke155 wrote: post #475
carlosjobim wrote: post #422

Earlier quoted context omitted.

> There is a general prohibition on EU member states granting state aid to companies The EU hands out billions in direct aid to companies every year. Many times together with the country governments. So there's no such prohibition in practice. In the EU regions I am familiar with, at least 70% of companies live on getting subsidies from the EU mainly and income from actual customers as a secondary concern. And I'm no…

The EU does that, yes. He’s saying countries can’t do that to their own industries, however, which I am led to believe is correct.

I think it applies only to aids for specific companies? e.g. if all companies that satisfies some requirements (e.g. N number of employees/new jobs , specific geographic area, industry etc.) cam receive the aid it's legal.

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

#485

Post by ribosometronome »

ajross wrote: post #461
nine_k wrote: post #385

Earlier quoted context omitted.

Specifically in Ireland, corporate taxes were being lowered from late 1980s until 2003, in a series of agreements with the EU regulators. It's not like Ireland lowered the taxes in a sneaky scheme, or grandfathered-in an abnormally low rate.

At the same time it's clear that Ireland has been "gaming the system" here, and the proof is the huge delta between the effective tax rates between member nations we're seeing in the judgement. I don't know that there's much of a moral or principled argument to be made here, every system gets gamed, and the European Commission is another such system. And Ireland absolutely agreed to be bound in that game as a price o…

Punishing Ireland for gaming the system by paying Ireland 13 billion hardly makes it seem like the EU is super concerned about Ireland's transgressions.

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

#487

Post by 1over137 »

TillE wrote: post #398
panzagl wrote: post #391

Earlier quoted context omitted.

If you don't like then... uh... come back?

You're free to renounce American citizenship to escape future tax obligations. Anyway it's not an issue for non-rich expats, you just have to file a tax return which shows you owe $0.

You also have to be fully up-to-date with the IRS before you can renounce citizenship!

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

#488

Post by koyote »

gamblor956 wrote: post #473
jandrewrogers wrote: post #366

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. 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…

Many types of income cannot be offset nor or they covered by tax treaties. That's news to me and I've been doing international tax for 15 years. Please, tell me what types of income earned by a U.S. expat isn't covered by a tax treaty? It is not uncommon to pay more taxes in aggregate as an expat than you would pay in either country separately. This is objectively false. For an expat, income taxes paid to a resident…

> Please, tell me what types of income earned by a U.S. expat isn't covered by a tax treaty?

I am not a tax person, but selling a house can cause you to owe tax in the US even if you did not owe any tax in the country you are living in (and sold the house in).

Famously one of the reasons Boris Johnson tried to give up his US citizenship (https://www.bbc.com/news/uk-politics-30932891).

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

#489

Post by gleenn »

gamblor956 wrote: post #473
jandrewrogers wrote: post #366

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. 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…

Many types of income cannot be offset nor or they covered by tax treaties. That's news to me and I've been doing international tax for 15 years. Please, tell me what types of income earned by a U.S. expat isn't covered by a tax treaty? It is not uncommon to pay more taxes in aggregate as an expat than you would pay in either country separately. This is objectively false. For an expat, income taxes paid to a resident…

My understanding, despite the fact I'm definitely not an accountant, was that making over $100K abroad meant you would be double taxed on all of it over that amount. I believe I heard many wealthy Americans abandoning their citizenship just due to this fact.

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

#490

Post by qwytw »

Aerroon wrote: post #302
kwhitefoot wrote: post #205

Earlier quoted context omitted.

So how come the US has worse health outcomes?

I'm not sure. I don't think anyone knows for sure, but obesity probably heavily factors into it. 53% of Europeans are overweight or obese. The same figure in the US is 72%. That's a 36% difference. More than that, 17% of Europeans are obese (BMI >30) compared to the US's 42%. The fact that the US has a life expectancy of 79.1 compared to the EU's 81.5 years with that kind of difference in obesity levels is actually s…

> compared to the EU's 81.5 years with that kind of difference in obesity levels is actually surprising

It's probably considerable higher in EU15 i.e. if we exclude all the poor (currently or previously) ex-socialist Central and Eastern European countries that have a lot of baggage

Or at least men in those countries:

https://ec.europa.eu/eurostat/statistics-explained/images/2/...

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