There should never be a gap this big unless fraud or evasion is involved. If the rules are that vague it needs to change.
Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
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Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#62“Many large multinationals use cost-sharing because it reflects the global nature of their business.” A comparable example might be Apple, where sales of my (american) app being sold from (american) servers somehow curiously involves the Republic of Ireland and their low corporate tax rates…
It's simple enough, an Irish company called Apple licenses its very valuable IP to its entities in cheaper countries so they can do things like manufacturing, server farms, customer support. (It also carries on these some of these functions in Ireland, as it happens, and pays a ton of tax at the relatively high income tax rates there.) It's frankly curious to me when a multinational chooses to base itself anywhere le…
The same applies to all the BS Delaware corporations.
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#63Earlier quoted context omitted.
Yank the ladder up? Are you a cryptocurrency / superstonk / Wall Street Bets poster or something? The SEC should be going after scams and cults as well as corporate tax, it's a false dichotomy you're proposing.
Actually no, but nice try, and I'm sure your extremist uninformed view of what's a "cult" is representative of the SEC's general posture.
https://news.ycombinator.com/item?id=9980141>
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#64Earlier quoted context omitted.
Then I'm not sure what you're worried about, if it really isn't a cult as you imply. Either way, I don't understand your position on the matter, are you personally affected by the SEC going after cryptocurrency scams and WSB style stock traders?
Yeah I think the SEC should work on real things instead of designating people as "cults" for running computer networks they dislike.
https://news.ycombinator.com/item?id=37839087>
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#65There should never be a gap this big unless fraud or evasion is involved. If the rules are that vague it needs to change.
Should we measure the gap in relative or absolute terms?
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#66“Many large multinationals use cost-sharing because it reflects the global nature of their business.” A comparable example might be Apple, where sales of my (american) app being sold from (american) servers somehow curiously involves the Republic of Ireland and their low corporate tax rates…
Apple pays the majority of taxes to US. They report US income and pay taxes for that to US. Ireland is involved only so far as EU income. So if your American app is sold to European users, the income is recognized as EU, and reported to Ireland.
https://fortune.com/2017/10/31/trump-tax-reform-apple-multin...
There are other possible criticisms on corporate tax and Apple, but this isn't a valid one.
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#67Earlier quoted context omitted.
At one point, it wasn’t an Irish company. Now technically the American company sold or transferred its IP to the Irish company. But it did so as a fiction, to avoid taxes, and neither I nor a government I help elect are obligated to honor that fiction.
It's no less fiction than any other contract or legal document.
Yes it is, because this one negatively affects enough people that the law should make a special case to disallow it. Contracts are enforceable when laws say they are enforceable, but governments are free to change laws.
If the government says it is a fiction, it is a fiction.
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#68Earlier quoted context omitted.
At one point, it wasn’t an Irish company. Now technically the American company sold or transferred its IP to the Irish company. But it did so as a fiction, to avoid taxes, and neither I nor a government I help elect are obligated to honor that fiction.
Of course they are, it’s a contractual agreement that is within the law. The fact that you don’t like it could not be less relevant, you don’t matter. If the government doesn’t like the law, they can (try) to change it but that has to go through the actual process. They are welcome to be as mad as they want that their law is poorly written but it is still their law.
I believe "their law" is what is being criticized, and GP's "government that I help elect" would do away with "their law." Pointing out that the law being criticized as bad is in fact a law is at best a tautology...
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#69Earlier quoted context omitted.
At one point, it wasn’t an Irish company. Now technically the American company sold or transferred its IP to the Irish company. But it did so as a fiction, to avoid taxes, and neither I nor a government I help elect are obligated to honor that fiction.
Of course they are, it’s a contractual agreement that is within the law. The fact that you don’t like it could not be less relevant, you don’t matter. If the government doesn’t like the law, they can (try) to change it but that has to go through the actual process. They are welcome to be as mad as they want that their law is poorly written but it is still their law.
As a voter, I’m OK with them not following the process on this one!
Re: Microsoft SEC 8-K: IRS is seeking an additional tax payment of $29B
#70Earlier quoted context omitted.
At one point, it wasn’t an Irish company. Now technically the American company sold or transferred its IP to the Irish company. But it did so as a fiction, to avoid taxes, and neither I nor a government I help elect are obligated to honor that fiction.
It's no less fiction than any other contract or legal document.
Although in this case, this was a good use of government time even if it goes to the courts! I would like to see the government instill a culture of fear in these companies’ legal departments, that leaves them wondering them the law will change to hit them.