patrick.net

thomaswong.1986 says

mell says

Nowadays where business mostly exist on a couple of servers, you can easily set up a corporation outside of the US where the business transactions will happen, and therefore skirt higher taxes (with some restrictions that a good lawyer can take care of). This is reality, not fiction, happening every day. Nobody is advocating an anarcho paradise.

your not skirting any taxes... how could you ? Your gonna get taxed by the home countries taxing authority and any foreign nations you do business with.

for USA companies, they pay domestic and foreign tax. there is a foreign tax credit used by corporations are there is one for individual tax payers.

there are no lawyers or accountants that can fix anything to hid transactions or skirt taxes..unless your completely working for a criminal organization.

Apparently Apple was able to do it and it wasn't illegal:

http://online.wsj.com/news/articles/SB10001424127887324787004578495250424727708

thomaswong.1986 says

You know of any regulations which would have stopped irrational exuberance /
speculation over the public infatuation over internet stock..or home prices ?

You want to regulate peoples actions.. but you dont know what actions they
will take which
creates speculations.. Beenie Babies anyone ?

Enforcing lending standards would have stopped the housing bubble.

mell says

Apparently Apple was able to do it and it wasn't illegal:

http://online.wsj.com/news/articles/SB10001424127887324787004578495250424727708

Alot of companies bugged out of continent due to litigation and high severance costs.. moved their HQ to UK or Ireland. Thats a question France, Italy, Germany and others have to deal with. And yes The Irish are very happy to get the tax dollars and require international companies to hire their citizens, the Irish are not complaining at all. What the Irish dont tax, gets taxed and is due to the US IRS.

For US IRS purposes its all Global income is taxable ....but we dont double tax the same international pre tax income. If less than statutory foreign tax is paid, the more US IRS collects.

http://www.irs.gov/Individuals/International-Taxpayers/Foreign-Tax-Credit

Foreign Tax Credit
If you paid or accrued foreign taxes to a foreign country on foreign source income and are subject to U.S. tax on the same income, you may be able to take either a credit or an itemized deduction for those taxes. Taken as a deduction, foreign income taxes reduce your U.S. taxable income. Taken as a credit, foreign income taxes reduce your U.S. tax liability. In most cases, it is to your advantage to take foreign income taxes as a tax credit.

The Journalist need to start asking the big 4 Accounting Firms how all this works.

page 61

http://investor.apple.com/secfiling.cfm?filingID=1193125-12-444068&CIK=320193

thomaswong.1986 says

You know of any regulations which would have stopped irrational exuberance / speculation over the public infatuation over internet stock..or home prices ?

Yes. Banking regulations forbidding banks from playing in the derivatives markets.

But they were repealed in the late 1990s, by Phil Gramm, Jim Leach, and Thomas Bliley, with the help of a compliant House and Senate, and a whore President with no guts to veto.

It once was the case that members of both parties believed in sensible regulation. A minority of Democrats now do, and nearly none in the Republican Party do, since it has now become a religious cult.

A flashback:

During debate in the House of Representatives, Rep. John Dingell (Democrat of Michigan) argued that the bill would result in banks becoming "too big to fail." Dingell further argued that this would necessarily result in a bailout by the Federal Government.

Hahaha! What a socialist asshole! Can you believe that Marxist, Stalinist, Castro-loving crap!

HydroCabron says

Hahaha! What a socialist asshole! Can you believe that Marxist, Stalinist, Castro-loving crap!

doesnt Dingell represent Detroit.. where is the beacon ?

thomaswong.1986 says

The Journalist need to start asking the big 4 Accounting Firms how all this works.

Why? It's not magic to read a 10-k, the journalists numbers look about right. Take Apples 10-k. Go to the line that says income, 55.7 billion. Then go to the statement of cash flows taxes paid, 7.7 billion giving a rate of 13.8%. Back out state taxes and foreign taxes (footnote #5) of 2.2 billion you come up with 5.3 billion for a tax rate of 9.5% which much higher than 2011 at 5.3%. Just a touch short of the 35% federal rate they are supposed to be paying to have their operations in the good old USA.

bob2356 says

Why? It's not magic to read a 10-k, the journalists numbers look about right. Take Apples 10-k. Go to the line that says income, 55.7 billion. Then go to the statement of cash flows taxes paid, 7.7 billion giving a rate of 13.8%

Journalist know shit!

Pg 61...A reconciliation of the provision for income taxes, with the amount computed by applying the statutory federal income tax rate (35% in 2012, 2011 and 2010) to income before provision for income taxes for 2012, 2011, and 2010, is as follows (in millions):

$ 19,517 / 55,763 = 35%

Again there is a difference between Gaap Pre-tax vs IRS reported taxable income..

Paid vs accrued (Liable) due to temp differences plus credits. what isnt paid is still taken to the P/L and will be paid once the temp differences expire Therefore the taxable income will be much less than 55B per GAAP. You really need the Tax return for that. A typical investor doesnt need such information.

http://en.wikipedia.org/wiki/Deferred_tax

http://www.youtube.com/embed/45PARid_erY

thomaswong.1986 says

Again there is a difference between Gaap Pre-tax vs IRS reported taxable income..

Paid vs accrued (Liable) due to temp differences plus credits. what isnt paid is still taken to the P/L and will be paid once the temp differences expire Therefore the taxable income will be much less than 55B per GAAP. You really need the Tax return for that. A typical investor doesnt need such information.

So you are saying apple is lying on the 10-k, the tax return will have a significant difference in numbers? I'm sure the investors would be very interested in that. Pretty amazing how those temp differences keep happening year after year after year after year. What decade do you project they will actually expire and apple will send a really huge check to the IRS?

Very interesting you get your tax accounting information from youtube and wiki. I guess journalists don't have access to those types of research resources. Anyway thank you for confirming what I suspected all along was the basis of your alleged tax knowledge.

bob2356 says

Very interesting you get your tax accounting information from youtube and wiki. I guess journalists don't have access to those types of research resources. Anyway thank you for confirming what I suspected all along was the basis of your alleged tax knowledge.

You don't know who your dealing with.

I'd back off, if I were you: thomaswong.1986 says he reads The National Review. You can't win against that kind of intellectual firepower!

thomaswong.1986 says

For US IRS purposes its all Global income is taxable ....but we dont double tax the same international pre tax income. If less than statutory foreign tax is paid, the more US IRS collects.

http://www.irs.gov/Individuals/International-Taxpayers/Foreign-Tax-Credit

Thomas, your comment is true for individuals. But the recent discussion is about companies. Apple USA Inc can do something that an individual cannot do; they can set up Apple Ireland Inc, assign the value of the patents to Ireland, say that the sales in EU are out of the Irish subsidiary. Apple USA Inc would only pay USA taxes on whatever Apple Ireland Inc pays to Apple USA Inc.

A person can't do this with W-2 income, as stated in your link. But that's not really relevant to this question of companies setting up subsidiaries in other places.