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Re:Apple's cash hoard swells to $246B by toomuchtodo on Saturday April 15, 2017 @03:51PM (#14122496)
We don't have to lower taxes. We just change the tax law to tax that money whether they bring it back to the US or not.
Re:Apple's cash hoard swells to $246B by drawkbox on Saturday April 15, 2017 @04:00PM (#14122534)
You could do that but it would create more games with headquarters being outside the US and even small businesses/medium businesses would start doing that. There would be a million loopholes around it.

I say corporations won the war, they have the legal teams to keep winning. As a response let small/medium sized businesses compete better by just lowing business taxes to really low levels, or progressive taxing as you grow. Right now the high tax rate only really affects our engine small/medium businesses who provide 50% of GDP, 65+% of jobs and 33% of exports.

The only companies paying taxes are small/medium businesses, the tax system here almost is a competitive advantage to large companies over small/medium. If larger companies aren't going to invest here, get competitive help to the small/medium companies and entrepreneurs that are to challenge them.

Re:Apple's cash hoard swells to $246B by sharun on Saturday April 15, 2017 @05:41PM (#14122996)
I don't know about corporations having all this wrapped up. There is a lot of pressure on them since 2008 plus one leak after another - Lichtenstein, Luxembourg, Panama, Switzerland etc hasn't made it easy to be tax haven. If they had "won the war" we wouldn't be discussing it here.
Re:Apple's cash hoard swells to $246B by drawkbox on Saturday April 15, 2017 @07:16PM (#14123389)
Many of those were personal income tax dodging, corporate tax dodging is usually island tax havens or Ireland recently (Apple/Facebook).

Personal income tax dodging is bad as that is where most tax revenue comes from. Taxes should probably be lower on income as well though to discourage tax games and retaining more tax whales (wealthy tax payers). People of all brackets need more money in their pocket for this consumer economy that hasn't really rebounded.

Re:Apple's cash hoard swells to $246B by toomuchtodo on Saturday April 15, 2017 @07:47PM (#14123488)
"Bloomberg: Sorry America, Your Taxes Aren’t High"

https://www.bloomberg.com/news/articles/2017-04-11/sorry-ame...

How low is low enough? Pay your damn taxes.

Re:Apple's cash hoard swells to $246B by drawkbox on Saturday April 15, 2017 @07:53PM (#14123521)
Only takes into account federal taxes (30%ish). There are state (3-5%), sales (6-10%), property (based on property), county taxes (less than 1%), self employment/FICA tax (15%). For small/medium business or pass-through business sole-proprietor/LLCs etc have a self-employment tax of about 15% on top of the income (for Social Security / Medicare i.e. FICA, regular employees pay half while the company pays the other half).

There are lots of taxes beyond income tax. Basically taxes take about .35-.50 out of every dollar earned through income, sales, other taxes. Business expenses for businesses, kids, credits and other things can help bring it down as well as standard deductions but it is still high.

Re:Apple's cash hoard swells to $246B by coliveira on Saturday April 15, 2017 @09:29PM (#14123869)
This seems a lot until you notice that really rich people don't pay these taxes. They make capital gains or receive dividends, which are either tax free or taxed at a much advantaged rate. This is why there is such a great separation between the 1% and the rest of the population.
Re:Apple's cash hoard swells to $246B by sjy on Saturday April 15, 2017 @11:41PM (#14124204)
The article specifically states that the OECD analysis estimated 'payroll taxes, federal income tax, state and local government taxes.'
Re:Apple's cash hoard swells to $246B by drawkbox on Sunday April 16, 2017 @12:01AM (#14124252)
"Excluded are the countless other ways that governments levy taxes, such as sales and value-added taxes, property taxes, and taxes on investment income and gains."

They also don't include self-employment tax (15%) and sales tax (6-10%). Sales tax and self-employment alone are over 20% close to 25% not counted in the article. Property tax can be close to 1% (depends on property), dividend taxes also aren't included (10-15%).

Re:Apple's cash hoard swells to $246B by valuearb on Saturday April 15, 2017 @04:16PM (#14122603)
So you are saying that you want Samsung to be able to build phones tax free in China, but Apple should pay 40%+ income taxes (CA+US) for doing so?

Please let me move all my retirement savings into foreign stocks before you pass this law, please.

Re:Apple's cash hoard swells to $246B by MarkMc on Saturday April 15, 2017 @10:31PM (#14124040)
California has enormous advantages in intellectual capital that outweigh a high tax rate.

Imagine it is 2007 and you can choose to invest in Apple and receive 60% of profits, or Samsung and receive 100% of profits. What's the better investment?

Re:Apple's cash hoard swells to $246B by opo on Sunday April 16, 2017 @02:02AM (#14124592)
>...Imagine it is 2007 and you can choose to invest in Apple and receive 60% of profits, or Samsung and receive 100% of profits. What's the better investment?

Imagine it is 2007 and you can choose to invest in Yahoo and receive 60% of profits, or Samsung and receive 100% of profits. What's the better investment?

Re:Apple's cash hoard swells to $246B by MarkMc on Sunday April 16, 2017 @11:54AM (#14126194)
That's a good point. But surely you accept that California has some inherant advantage? If the effective tax rate is 15% in South Korea and 20% in California, investors will still pour money into Silicon Valley won't they?
Re:Apple's cash hoard swells to $246B by opo on Sunday April 16, 2017 @05:29PM (#14127627)
>...But surely you accept that California has some inherant advantage?

For now at least, it does seem to have an advantage and draws capital. (For example, Samsung has a huge R&D center in silicon valley.) Of course for every successful IPO in the valley, there are many others who don't make it near that far.

The original poster was saying "...We just change the tax law to tax that money whether they bring it back to the US or not.". This would mean for example, that when selling in China, Apple would have to pay Chinese AND US/CA taxes on the profits made there and Samsung wouldn't - this would put US corporations at a huge disadvantage to their competitors. While I can see the goal is to get more tax money from corporations, it is obvious to see there would be a number of unintended consequences.

Re:Apple's cash hoard swells to $246B by MarkMc on Monday April 17, 2017 @10:09AM (#14130962)
I'm still not sure the original poster is wrong. Yes, Apple's would be at a disadvantage due to higher tax rates but maybe that would be offset by the inherant advantages that California offers tech companies. If such advantages are strong enough to overcome a 5% difference in tax rates with South Korea, maybe they are strong enough to overcome a 40% difference. Investors will moan and complain but ultimately they will continue to find startups in California because it still offers the best return on investment.
Re:Apple's cash hoard swells to $246B by opo on Monday April 17, 2017 @01:33PM (#14132806)
>...Yes, Apple's would be at a disadvantage due to higher tax rates but maybe that would be offset by the inherant advantages that California offers tech companies.

What you are forgetting is that US law doesn't discriminate against foreign owned companies. (Which is good - it encourages investment in the US.) So if a corp with US headquarters would pay 30-40% taxes on profits made in non-US countries, this would make those companies very uncompetitive against a foreign company.

>...they will continue to find startups in California because it still offers the best return on investment.

If something like this was done, there may still be lots of money invested in CA, but eventually it would be mostly companies with a HQ outside of the US.

Re:Apple's cash hoard swells to $246B by MarkMc on Tuesday April 18, 2017 @01:47PM (#14141073)
The thing is, Apple hasn't really made those profits in a foreign country - there is very little profit to be made from manufacturing mobile phones in China which is why Apple outsources this task to Foxconn. There is also little profit to be made in selling phones - if Apple's retail arm was a separate company it would have no leverage to negotiate a good deal.

The bulk of Apple's profit has come from design, marketing and engineering by employees, plus outstanding judgment and leadership by Steve Jobs. Those things were done in California. The problem is that Apple uses accounting tricks to transfer the profit to Nevada or Ireland or some other low-tax jurisdiction.

It doesn't matter where the company's headquarters are located. If Samsung has profitable operations in California it should be taxed on that activity at the same rate as any other Californian business. That leads to another point - there are plenty of Californian businesses which cannot use the same accounting tricks that Apple uses. So you have a situation where two businesses that draw from the same pool of resources pay different tax rates. It could be that Business A uses those resources more efficiently but Business B gets funding because its tax rate is lower. That strikes me as inefficient.

Running a business in California is like growing crops in a particularly fertile field. You get a great yield, but you should also pay high rent.

Re:Apple's cash hoard swells to $246B by opo on Tuesday April 25, 2017 @01:39AM (#14191064)
You are bringing up a few new issues here.

In regards to Apple, Tim Cook in his testimony to congress said:

>...The Company’s FY2012 total US federal cash effective tax rate was approximately 30.5%.1

>…Apple does not use tax gimmicks. Apple does not move its intellectual property into offshore tax havens and use it to sell products back into the US in order to avoid US tax; it does not use revolving loans from foreign subsidiaries to fund its domestic operations; it does not hold money on a Caribbean island; and it does not have a bank account in the Cayman Islands. Apple has substantial foreign cash because it sells the majority of its products outside the US. International operations accounted for 61% of Apple’s revenue last year and two-thirds of its revenue last quarter. These foreign earnings are taxed in the jurisdiction where they are earned (“foreign, post-tax income”).

https://www.apple.com/pr/pdf/Apple_Testimony_to_PSI.pdf

>...It doesn't matter where the company's headquarters are located.

If you are a US company, it does.

>...If Samsung has profitable operations in California it should be taxed on that activity at the same rate as any other Californian business.

It is. The difference is that Samsung subsidiaries that make a profit in Germany don't have to South Korea corporate tax when they want to invest in South Korea. In fact, the US is the ONLY country (other than Eritrea) that does this - every other country has figured out that this discourages bringing investment capital back to the home country. The guy who posted the original snarky post about just taxing all the worldwide income of a US corp didn't try to defend it when people posted some of the more obvious consequences. US companies need a level playing field against the companies from other countries

>...That leads to another point - there are plenty of Californian businesses which cannot use the same accounting tricks that Apple uses.

I think you are referring to how some of the big corps essentially pay no US corporate tax. A number of economists have said a much better system would be a revenue neutral system where you remove the corporate tax and increase taxes on capital gains and dividends as that is much easier to tax and corporate taxes tend to hurt the workers in a company and hurt the consumer by increasing prices. But that is a different issue.

>...Running a business in California is like growing crops in a particularly fertile field. You get a great yield, but you should also pay high rent.

CA has unique strengths and weaknesses for a business. There are smart people all over the world so there is no absolute guarantee that CA will do as well 40 years from now as it has done over the 40 years, but that again is a different issue and worthy of its own discussion.

Re:Apple's cash hoard swells to $246B by toomuchtodo on Saturday April 15, 2017 @07:28PM (#14123432)
Feel free. Enjoy your already bond-level returns that asset class enjoys.
Re:Apple's cash hoard swells to $246B by vnchr on Saturday April 15, 2017 @03:58PM (#14122530)
Technically, that would require taxing a foreign company for foreign business activity. It's out of the US's jurisdiction.
Re:Apple's cash hoard swells to $246B by seanmcdirmid on Saturday April 15, 2017 @05:26PM (#14122938)
It might work if we use our military to make all companies pay USA taxes no matter if the money is earned abroad and/or by a foreign company. /s

No, this isn't workable.

Re:Apple's cash hoard swells to $246B by toomuchtodo on Saturday April 15, 2017 @08:50PM (#14123747)
Pay your taxes or don't sell your products in the country.

Don't say something can't be done when it can easily be done. We'll embargo your goods at container ports and land borders if necessary. If you're a digital company, we will drop your ASN traffic at the border.

Donald Trump becoming president is fairly indicative that nothing is off the table.

Re:Apple's cash hoard swells to $246B by seanmcdirmid on Saturday April 15, 2017 @09:29PM (#14123870)
Hey, there are two companies, IBM and SAP. They both do a lot of business abroad, pay taxes abroad, and whatever.

Now which one do you want to pay all their taxes on all their international income? IBM? SAP? Pick carefully: why should SAP have a competitive advantage over IBM?

Digital companies ALREADY pay taxes for everything that happens INSIDE of the USA. What we are arguing about is stuff that occurs OUTSIDE of the USA.

Donald Trump becoming president simply means crazy idiotic proposals are now on the table. But then again he is realizing "gosh, this is really hard, not as easy as I thought" like health care, wall building, labelling china a currency manipulator, tax reform, etc...

Re:Apple's cash hoard swells to $246B by toomuchtodo on Sunday April 16, 2017 @12:33AM (#14124337)
> Donald Trump becoming president simply means crazy idiotic proposals are now on the table.

I'm actually pretty fond of some of his proposals, such as deporting illegal immigrants who have committed crimes and making it much more difficult to hire H1Bs (I don't like many other policies he's put forth, but you can't get everything you want); but then, that's what happens when both parties ignore a large chunk of America. Public policy starts coming down the pipe that gets called "crazy idiotic", and then its policy.

American citizens are taxed on all worldwide income, why is it crazy that businesses should be as well? If you pay taxes to some other country, sure, you get a deduction for that. But tax accounting fuckery where you're paying no taxes on a large amount of income? Nope.

https://en.wikipedia.org/wiki/Double_Irish_arrangement

Re:Apple's cash hoard swells to $246B by seanmcdirmid on Sunday April 16, 2017 @12:36AM (#14124345)
Illegal immigrants who committed crimes were being deported before Trump, H1Bs were already difficult to hire and so on. To be honest, I don't care what Trump does as long as he doesn't start a huge ass war or crash the economy, and I have honest fears that both of those are a possibility from someone who finds every so much harder than he thought.
Re:Apple's cash hoard swells to $246B by Animats on Saturday April 15, 2017 @04:08PM (#14122572)
Nah. Apple's "foreign business activity" in Ireland is a tax dodge.
Re:Apple's cash hoard swells to $246B by mcphage on Saturday April 15, 2017 @04:18PM (#14122615)
It is, but it's a dodge based on money from products manufactured and sold outside of the US, owned by a company not in the US, so it's still not clear how the US could legally insert themselves into there.
Re:Apple's cash hoard swells to $246B by icebraining on Saturday April 15, 2017 @05:42PM (#14122998)
Isn't Apple Ireland owned by the US company?
Re:Apple's cash hoard swells to $246B by valuearb on Saturday April 15, 2017 @04:17PM (#14122611)
What is Samsung's foreign business activity? Cause it doesn't pay US income taxes on it, ever.
Re:Apple's cash hoard swells to $246B by briandear on Saturday April 15, 2017 @07:37PM (#14123456)
Why? It was earned outside the US so how does the US have any moral claim to it?
Re:Apple's cash hoard swells to $246B by bonaldi on Saturday April 15, 2017 @08:43PM (#14123719)
The US lays claim to income tax on its citizens' earnings outside the US, even when they're wholly resident in other countries, so ...
Re:Apple's cash hoard swells to $246B by IncRnd on Saturday April 15, 2017 @10:18PM (#14124004)
That doesn't make much sense in this case. You can't arbitrarily tax foreign corporations that aren't on US soil.
Re:Apple's cash hoard swells to $246B by lsadam0 on Saturday April 15, 2017 @04:29PM (#14122667)
I hope you never hold public office. Please, if you plan to run, let me know so that I can adjust my investments accordingly.
Re:Apple's cash hoard swells to $246B by toomuchtodo on Saturday April 15, 2017 @07:30PM (#14123436)
I don't care about your investments, I care about entities paying their taxes.
Re:Apple's cash hoard swells to $246B by IncRnd on Saturday April 15, 2017 @10:21PM (#14124020)
Why do you think a foreign company should pay US taxes?
Re:Apple's cash hoard swells to $246B by Frondo on Sunday April 16, 2017 @02:46AM (#14124706)
Apple isn't a foreign company.
Re:Apple's cash hoard swells to $246B by IncRnd on Tuesday April 18, 2017 @04:24PM (#14142559)
Except that the foreign company which profited by 246B is foreign. If it weren't foreign, then taxes would have been paid to the US on the monies as they were made, and there wouldn't be close to that amount of money offshore. As the article says, "Repatriation is front and center. That is good for the country and Apple." That is different from envious theft.

There is more than one company called Apple. Which one do you mean?

Re:Apple's cash hoard swells to $246B by intended on Saturday April 15, 2017 @11:13PM (#14124142)
Is the point not about tax evasion?
Re:Apple's cash hoard swells to $246B by IncRnd on Sunday April 16, 2017 @12:11AM (#14124275)
No. It is not even clear this is tax avoidance, let alone evasion. No country on Earth taxes companies that are foreign to it, unless they do business inside the borders.
Re:Apple's cash hoard swells to $246B by opo on Sunday April 16, 2017 @02:01AM (#14124588)
So are you recommending that a foreign company should only pay taxes on what they earn in the US, but a US company should pay taxes on everything it earns everywhere? (i.e. the US government should get 36% of the profits even if something is built/sold in another country, just because the company has its headquarters in the US?) You do realize this would put US corporations at a huge disadvantage to corporations in any other country, right? You can imagine some of the unintended consequences.

I think only Eritrea and the US taxes corporations when brining back money into the country. For obvious reasons other countries realized this was not a good approach and don't do that.

Re:Apple's cash hoard swells to $246B by simonh on Sunday April 16, 2017 @03:58AM (#14124877)
That would massively disadvantage US companies operating abroad, compared to foreign companies. E.g. Ford builds a car in Spain, ships it to France and sells it. They pay a US tax to do so. VW does the same, but pays no US tax, therefore the VW car will be cheaper. It would kill US companies global competitiveness.
Re:Apple's cash hoard swells to $246B by sigzero on Saturday April 15, 2017 @05:57PM (#14123070)
You would have to radically change tax laws and likely it would not stand up to the courts.