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

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

#71
post #29

Earlier quoted context omitted.

We all know the answer. Because all governments feel they should spend that money instead of Apple. And they can take it, so they should. And the more left-leaning part of the aisle has this idea that they will get to decide what that money will be spent on. So they support this. (I'm not rightist, in fact I'm probably extreme left by American standards, but I just don't believe the government is on the people's side…

Yeah, or, Apple benefits handsomely from money spent on their behalf by the federal and local governments (e.g. the roads and public transit infrastructure serving their headquarters, the funding for the public universities and subsidized loans for private universities from which they draw their employees), but apparently doesn't feel any obligation for funding those benefits. It's not about "feeling that they can sp…

"Their share" is exactly what's up for debate. You make it sound like the US Government has a number and they're failing to collect because Apple is strong arming them. The US Government has the largest military in the world by a far margin and Apple has roughly zero physical might. If the US wants Apples money they can easily take Apples money. Until that point they're just talking.

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

#72
post #10

Earlier quoted context omitted.

What Apple owes is clear to me: pay the standard U.S. corporate tax on the standard U.S. profits. Do the same for all countries. The Apple problem is that its lawyers are deliberately avoiding using current tax codes, and instead essentially claiming that Apple is based in Ireland, then playing shell games with what counts as U.S. sales, U.S. profits, and also U.S. property. Apple ends up paying ~10% U.S. tax, rather…

No! No! No! What you legally owe in taxes, in a reasonable tax structure, has NOTHING to do with your moral compass. You should be able to plug numbers into a spreadsheet and get it. I'm not saying that taxes are bad. We need tax revenue. I get that. But there should NEVER, EVER, be two legally correct answers to how much you owe. The fact that you had to spend paragraphs making your case, makes mine -- when you reso…

You may not realize this, but there is a similiar argument happening in the Accounting world. You are basically arguing for Rules (Clear, Bright Lines) instead of Principles: There is already a current debate about this in the accounting world in GAAP vs IFRS and it has nothing to do with morality.

One of the advantages of GAAP, as you seem to be arguing is the reduction of risk since the rules are clear, unfortunately, the downside is the ability to circumvent them.

it is also funny how investors feel about accounting standards when it is THEIR money at risk and not the governments.

https://ifrsusa.wordpress.com/2011/04/05/which-is-better-%E2...

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

#73

Earlier quoted context omitted.

No! No! No! What you legally owe in taxes, in a reasonable tax structure, has NOTHING to do with your moral compass. You should be able to plug numbers into a spreadsheet and get it. I'm not saying that taxes are bad. We need tax revenue. I get that. But there should NEVER, EVER, be two legally correct answers to how much you owe. The fact that you had to spend paragraphs making your case, makes mine -- when you reso…

You may not realize this, but there is a similiar argument happening in the Accounting world. You are basically arguing for Rules (Clear, Bright Lines) instead of Principles: There is already a current debate about this in the accounting world in GAAP vs IFRS and it has nothing to do with morality. One of the advantages of GAAP, as you seem to be arguing is the reduction of risk since the rules are clear, unfortunate…

Excellent point. I strongly prefer IFRS over US GAAP, for exactly your reasons. IFRS tends to favor principles, GAAP tends to favor rules.

The ideal (IMHO) is to improve the principles and rules together, and Apple is in a unique leadership position to do this.

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

#74
post #4

Earlier quoted context omitted.

Forbes is using the 'FuckAdblock' thing... so yes, it doesn't work when you're using Adblock. But if you install the FuckFuckAdblock extension, you should be able to see the article. Here's a link to the extension: https://chrome.google.com/webstore/detail/fuckfuckadblock/hb...

I thought you were kidding until I clicked the link. Probably named with intent to inspire comments just like yours. Lmao.

Hah :) So, as it happens, I was just last night talking to a guy who was basically attempting to make a 'FuckFuckFuckAdblock' -- a js solution to detecting the presence of FuckFuckAdblock extension. (I'm not sure how far he got, I'll try getting in touch with him soon to see how that's going. And, the guy was looking into creating this just for kicks, he's not in the ads industry). Anyway, so naturally we might very well soon be seeing a FuckFuckFuckFuckAdblock extension (or F^4, if you would).

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

#75
post #4

Earlier quoted context omitted.

Forbes is using the 'FuckAdblock' thing... so yes, it doesn't work when you're using Adblock. But if you install the FuckFuckAdblock extension, you should be able to see the article. Here's a link to the extension: https://chrome.google.com/webstore/detail/fuckfuckadblock/hb...

Worked for me using Ad Block Plus.

I use microAdblock Origin, and Forbes doesn't work for me. Only with FuckFuckAdblock does Forbes work for me.

p.s.: you should use microadblock origin over ABP -- search past HN discussions for why it's preferable :)

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

#76

It's great how we're living in a world where tax codes are so idiotic and complex that it takes long lawsuits to figure out what tax is actually due. It's not about following the letter of the law; it's about following the letter of the law, avoiding the court of public opinion, and coughing up whatever is necessary to stop the complaints when some politician wants to distract people from their incompetence and whip…

>How about, we admit corporate income tax is a stupid idea, get rid of it, and raise capital gains taxes

Technical reasons why that doesn't work - basically it makes it too easy to avoid all tax by keeping the money in corporations.

What we need is a unified global tax regime for international corporations so they can't play off each countries tax loop holes.

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

#77
post #23

Earlier quoted context omitted.

Due to the way they leverage their foreign subsidiaries, they're able to play accounting games that drastically lower the perceived (and taxable) profit of those US sales. Such as this mentioned at [1]: "ASI [an Irish Apple subsidiary] buys Apple products from a Chinese manufacturer, resells them at a “substantial” markup to other Apple affiliates and retains the profits, the report said." [1] http://www.macworld.com…

What you're claiming is that Apple is engaging in Transfer Pricing ( https://en.wikipedia.org/wiki/Transfer_pricing ) which is blatantly and totally illegal. If that is in fact the case, then no laws need to be changed and everyone at Apple who knew about this should be subject to criminal prosecution. The article you posted however gives no evidence that Apple is actually engaging in such practices, or I assume they…

Transfer pricing is not illegal. It's often an element of illegal schemes to reduce tax but the act of setting prices between non-arms-length companies is not illegal. It's necessary. The prices just have to be what an arms-length company would pay.

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

#78
post #10

It's great how we're living in a world where tax codes are so idiotic and complex that it takes long lawsuits to figure out what tax is actually due. It's not about following the letter of the law; it's about following the letter of the law, avoiding the court of public opinion, and coughing up whatever is necessary to stop the complaints when some politician wants to distract people from their incompetence and whip…

What Apple owes is clear to me: pay the standard U.S. corporate tax on the standard U.S. profits. Do the same for all countries. The Apple problem is that its lawyers are deliberately avoiding using current tax codes, and instead essentially claiming that Apple is based in Ireland, then playing shell games with what counts as U.S. sales, U.S. profits, and also U.S. property. Apple ends up paying ~10% U.S. tax, rather…

When Apple designs a phone in CA, buys supplies from companies located in a dozen different countries, assembles it in China and sells it in Australia what tax should be paid and to whom?

These aren't "tax loopholes." They're legitimate rules to answer this fairly complicated question.

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

#79
post #69

It's great how we're living in a world where tax codes are so idiotic and complex that it takes long lawsuits to figure out what tax is actually due. It's not about following the letter of the law; it's about following the letter of the law, avoiding the court of public opinion, and coughing up whatever is necessary to stop the complaints when some politician wants to distract people from their incompetence and whip…

It's one of the great misconceptions. You can't tax a corporation, you can only tax people.

You can tax corporations. They of course will be owned by people until the AIs take over.

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

#80
post #78
post #10

Earlier quoted context omitted.

What Apple owes is clear to me: pay the standard U.S. corporate tax on the standard U.S. profits. Do the same for all countries. The Apple problem is that its lawyers are deliberately avoiding using current tax codes, and instead essentially claiming that Apple is based in Ireland, then playing shell games with what counts as U.S. sales, U.S. profits, and also U.S. property. Apple ends up paying ~10% U.S. tax, rather…

When Apple designs a phone in CA, buys supplies from companies located in a dozen different countries, assembles it in China and sells it in Australia what tax should be paid and to whom? These aren't "tax loopholes." They're legitimate rules to answer this fairly complicated question.

When the income ends up on the books and taxed only in Ireland, after expensing most of it as licensing fees to a shell company in Bermuda, despite none of those things (design, sourcing, manufacturing, assembly, sales) occurring in either country, it starts looking more like a loophole than legitimate rules around taxing an international business.
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