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U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

nytimes.com

81–90 of 164 posts

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#81
post #55

Earlier quoted context omitted.

And the US double taxes their citizens living abroad the same way. As an American making the same money as your non-american co-worker you are left with a lot less just for having a US passport. It is even possible you have never set foot in the US yet are required to pay uncle sam's taxes. Wanna get rid of your US passport? Not before you pay 10 years projected taxes and pay an abhorrent fee. You will also be listed…

> And the US double taxes their citizens living abroad the same way. The tax code has provisions to avoid "double taxes" on foreign income. You file Form 1116 to claim credit for taxes you paid to a foreign country as an offset against your U.S. tax liability.[1] That tax credit is separate from the income exclusion, which excludes the first ~$100k of foreign income from U.S. taxation. Generally, your total tax liabi…

I think the big injustice is that people don't have a right to a jury in tax court.

Therefore judgments are enforced without the consent of the people.

Therefore taxation in the USA today is extortion.

All the quibbling about the ridiculous bureaucratic rules and forms just makes it even more clear just what a leviathan our tax system has become.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#82
post #61

Earlier quoted context omitted.

Greatness aside, you probably couldn't have become rich without roads, national defense, clean water...

Those things aren't exclusive to the US.

Yes, but if you earned your billion on the backs of US peoples and infrastructure, you have to pay a toll when you leave.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#83
post #40

Earlier quoted context omitted.

The fist $100,000 income isn't taxed this way[1]. And it's not abhorrent. If you earned enough money to think it's advantageous to lose one of the most valuable passports in the world, you probably earned that money in large parts due to the support of the people and infrastructure of the United States. You don't get to drop your duties once you win big. [1] $97,600 for 2013, $99,200 for 2014 and $100,800 for 2015

>you probably earned that money in large parts due to the support of the people and infrastructure of the United States Or, you know, not. It's ridiculous to suggest that if you earn money abroad, American people and infrastructure are largely responsible for your success. It's in Dutch, but feel free to translate: http://nos.nl/nieuwsuur/artikel/2044332-amerikaanse-belastin...

I was talking about people renouncing their US citizenship to avoid American taxes.

That article is talking about renouncing their US citizenship to avoid an administrative nightmare. The people mentioned in that article probably owed little to nothing, but just didn't realize or didn't handle the finer details of their dual-citizenship very well.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#84
post #55

Earlier quoted context omitted.

And the US double taxes their citizens living abroad the same way. As an American making the same money as your non-american co-worker you are left with a lot less just for having a US passport. It is even possible you have never set foot in the US yet are required to pay uncle sam's taxes. Wanna get rid of your US passport? Not before you pay 10 years projected taxes and pay an abhorrent fee. You will also be listed…

> And the US double taxes their citizens living abroad the same way. The tax code has provisions to avoid "double taxes" on foreign income. You file Form 1116 to claim credit for taxes you paid to a foreign country as an offset against your U.S. tax liability.[1] That tax credit is separate from the income exclusion, which excludes the first ~$100k of foreign income from U.S. taxation. Generally, your total tax liabi…

[deleted]

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#85
post #45
post #37

Earlier quoted context omitted.

its very typical for people to want their cake and eat it too. They want the benefits of having the US passport but don't want to pay for it.

Or, consider that when you're born in the US you become a US citizen. There was a fuss in the Netherlands recently where some Dutch people who were born in the US but were only there very briefly as a baby, and as such lived a Dutch life in the Netherlands. The article I linked goes into how much of an absolute pain it is to renounce citizenship. Article in Dutch: http://nos.nl/nieuwsuur/artikel/2044332-amerikaanse-b…

If you're born in America, you're American. It's very simple.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#86
post #55

Earlier quoted context omitted.

> And the US double taxes their citizens living abroad the same way. The tax code has provisions to avoid "double taxes" on foreign income. You file Form 1116 to claim credit for taxes you paid to a foreign country as an offset against your U.S. tax liability.[1] That tax credit is separate from the income exclusion, which excludes the first ~$100k of foreign income from U.S. taxation. Generally, your total tax liabi…

I think the big injustice is that people don't have a right to a jury in tax court. Therefore judgments are enforced without the consent of the people. Therefore taxation in the USA today is extortion. All the quibbling about the ridiculous bureaucratic rules and forms just makes it even more clear just what a leviathan our tax system has become.

Many democratic countries have courts without juries. E.g. in France (and in many other countries in Continental Europe, because Napoleon) only the Cour d'assises, which has jurisdiction on serious crimes, has lay judges (not exactly the same as jurors, but close enough). All the other courts, including all the appellate courts, have professional judges only.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#87

Earlier quoted context omitted.

They do. But it doesn't work even in the US's case. US companies will routinely "sell" their intellectual property to a subsidiary in e.g. Ireland and then license to back to the US company to avoid paying US taxes. There are some highly successful US companies who, per the books, make nearly $0/year profit within the US.

They should charge executives Irish income taxes if they pull that off. (While Ireland's corporate taxes are low, their personal taxes are ~59% over ~100k, and that _includes_ capital gains, and a lot of things that are tax advantaged in the states)

[deleted]

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#88
post #72
post #55

Earlier quoted context omitted.

> And the US double taxes their citizens living abroad the same way. The tax code has provisions to avoid "double taxes" on foreign income. You file Form 1116 to claim credit for taxes you paid to a foreign country as an offset against your U.S. tax liability.[1] That tax credit is separate from the income exclusion, which excludes the first ~$100k of foreign income from U.S. taxation. Generally, your total tax liabi…

It's perhaps not a big injustice as far as these things go, but it is not fair either. I easily lost out on a thousand dollars of lost wages, accounting fees, and general hassle and stress doing my US taxes in Italy last year.

I think this is something that people who don't live abroad often have trouble grasping.

"Well, you left so you don't get to complain"

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#89

This is happening because unlike almost every other developed nation the US has a worldwide tax system. Almost every other nation has a territorial tax system. The rest of the world with their territorial system taxes income earned within that country, the US rather taxes income worldwide, regardless of where it is earned. For example, if a British company earns income in Germany, its pays German taxes on its German…

I thought the issue was that companies acquire say an Irish company and then instead of 35%, they are paying 10% and then instead of paying taxes in the US, they figure out how to move around goods and services to make it look like the profit was territorially gained in Ireland when in fact it was in the US. That is the issue. The greed is typically on the corporate side, more so than the government.

Re: U.S. Moves to Thwart Use of Foreign Acquisitions to Dodge Taxes

#90

Earlier quoted context omitted.

And the US double taxes their citizens living abroad the same way. As an American making the same money as your non-american co-worker you are left with a lot less just for having a US passport. It is even possible you have never set foot in the US yet are required to pay uncle sam's taxes. Wanna get rid of your US passport? Not before you pay 10 years projected taxes and pay an abhorrent fee. You will also be listed…

The fist $100,000 income isn't taxed this way[1]. And it's not abhorrent. If you earned enough money to think it's advantageous to lose one of the most valuable passports in the world, you probably earned that money in large parts due to the support of the people and infrastructure of the United States. You don't get to drop your duties once you win big. [1] $97,600 for 2013, $99,200 for 2014 and $100,800 for 2015

> you probably earned that money in large parts due to the support of the people and infrastructure of the United States. You don't get to drop your duties once you win big.

i agree. the american people and their infrastructure owe their existence to the british crown.

so, anytime you can send that check, that would be great.

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