This is not portrayed accurately. If you pay German taxes, you claim exception for that amount. So if you pay more taxes than the rate in US, you owe no tax for that income in US. If the rate is less in the country than in US, you pay the difference.
> But all this has now changed
I live in Australia. As a casual outside observer, can you inform me as to whether this tax bill has passed in to legislation, or is likely to?
The opposing party is not threatening shutdown. A group within the majority is. Since that group within the majority party won't play ball, the majority of the majority party is hoping to garner some support from the minority party.
As it happens, some of the changes they want to make would require 60% of votes rather than just 50%+1, but they haven't yet demonstrated they can get to 50%+1, so that's irrelevant here.
We live in a rules based system and the rules should be designed to incentivize the behaviors we want. Expecting any business to deviate from whats in their best interest is just... out of touch with reality.
- I’m not free to move anywhere I wasn’t invited nor is anyone paying my trip there.
All in all, death and taxes as they say.
Now they are paying the US gov. Unless they can keep coming up with more Irish tax avoidance schemes, going forward they will probably also have to pay in Europe.
They did not pay much tax on their profits in Germany, but it's debatable which part of the profit of a firm designing phones in the US and building them in China should fall to Germany.
Because those are EU countries and Apple has a tax deal with Ireland in the EU.
Regardless of this, stopping the flow of capital and investment into the country with a 35% tax is extremely dumb. Everyone will say effective is far less, but it's far less because of foreign profits and IP stashed in Ireland and effective may be 20% for tech, but marginal to bring back in the states is still 35%
But if you are a non-citizen who is a resident for tax purposes, then yeah you are out of luck.
^ Not meant as sarcasm, just noting the possible reason the spellchecker gets confused.
My mention of misspelling was there only to prevent another person from pointing it out, but alas, I still failed it seems.
jumping through literal hooves would be hilarious.. lol
This thread was about US citizens living abroad, which is a whole different issue.
No they're not. You're confusing the already commonly-confused concept of legal personhood with citizenship.
> but they can contribute unlimited campaign contributions
Citizens United ruled that actual human beings had the right to make unlimited campaign contributions and that the right to do so could not be rescinded just because those flesh-and-blood individuals decided to pool their money into a corporation. People have the right to organize for political action and congress cannot take that away.
No, it didn't. Campaign contributions are still limited.
Citizens United built on the established precedent that people unaffiliated with campaigns are free to spend their own money how they wish, as long as they don't coordinate with campaigns.
Citizens United ruled that this right applies to people who pool their money together.
If I have pooled my 'right of personhoop' contributions into a corporate asset base and thus absolved myself of liability laws regarding the disposition of this asset base -- what basis do I have to have to claim 'my' personhood rights over how this asset base is distributed to political campaigns?
If what you say is _actually_ true then it should be illegal for corporations to disperse campaign funds in anything other than an amount that _exactly_ reflects the relative ownership amount of every single stockholder in that corporation -- otherwise an individual shareholder's claim on the percentage of personhood ownership of the corporation has been rescinded.
A corporation still cannot make unlimited campaign donations. They can however spend their money however they choose. As long as they are not coordinating with any compaign.
If a candidate is running and promises to raise income tax to 99%, then I can form a political action committee or corporation and spend as much money as we want trashing the candidate that is pushing that idea. We cannot, however, donate unlimited funds to his opponent or work directly with any campaign, pay their expenses, etc.
It is a perfectly reasonable freedom that just happens to have negative consequences.
This won't stop companies selling their IP to overseas shells and then paying royalties.
For example, if a British company earns income
in Germany, its pays German taxes on its German
income. But if a US company earns income in
Germany it pays both German taxes and US taxes.
Isn't that money new income for the British company, and therefor would be taxed accordingly? I think that's the key here.
E.g. Starbucks in Germany... they buy their coffee from Sbucks Luxembourg, the amount of coffee needed to make a 7 euro coffee will also cost close to 7 euros, payable to the seller, Sbucks Luxembourg. So the German subsidiary has very low profits (7 euros for coffee beans for 1 cup of coffee!), and pay very little taxes. The Luxembourg subsidiary pay the local taxes, which are much lower -- as arranged by their then premier, and now current head of European Commission, Jean-Claude Juncker:
> In early November 2014, just days after becoming head of the commission, Juncker was hit by media disclosures—derived from a document leak known as LuxLeaks—that Luxembourg under his premiership had turned into a major European centre of corporate tax avoidance. With the aid of the Luxembourg government, companies transferred tax liability for many billions of euros to Luxembourg, where the income was taxed at a fraction of 1%. Juncker, who in a speech in Brussels in July 2014 promised to "try to put some morality, some ethics, into the European tax landscape", was sharply criticised following the leaks.[52] A subsequent motion of censure in the European parliament was brought against Juncker over his role in the tax avoidance schemes. The motion was defeated by a large majority.[53]
> In 2017, leaked diplomatic cables show Juncker, as Luxembourg’s prime minister from 1995 until the end of 2013, blocked EU efforts to fight tax avoidance by multinational corporations. Luxembourg agreed to multinational businesses on an individualised deal basis, often at an effective rate of less than 1%.[54]
If you buy something from European Amazon, the bill will be from Amazon Luxembourg. Same with Apple and Ireland...
If you have income from multiple sources, some of which may be in the U.S. and some not, even if it's as simple sideline business, then it gets more complicated as you also have to calculate profit/loss for that as if it were in the U.S., then subtract your taxes paid in your country, and demonstrate that it's all below a certain threshold. And there's also payroll tax exemptions, etc.
This isn’t entirely accurate (heh, taxes are complicated). The company would most likely pay VAT/sales tax in Germany, but would pay corporate/income tax in the U.K. If your customer is a VAT registered business you would usually exclude the VAT, unless they are based in the same jurisdiction as you (it doesn’t matter where the item is going).
Up until 2015 this wasn’t the case for digital goods as VAT was charged at the ‘place of supply’ (where the company was based), but it is now accounted for where your customer is located. This is what caused the VAT MOSS kerfuffle, as you now need to account for 28 sets of tax rules depending on where your customer is located.
Or, like Apple have a double Irish with a Dutch sandwich.
http://www.independent.co.uk/news/business/news/eu-takes-ire...
For example, if a British company earns income in Germany, its pays German taxes on its German income. But if a US company earns income in Germany it pays both German taxes and US taxes.
What is little known about this tax bill is that it normalizes our tax system with the rest of the world by moving to a territorial tax system. This is not about Apple avoiding tax on profit earned in the US, they will continue to pay US taxes, they won't pay taxes on income earned outside of the US going forward. [0] That means that there won't be any more hordes of overseas profits. And means the end of those tax inversions or corporate inversions you have been hearing about. [1]
So now that foreign profits aren't going to be taxed, something needed to be done with all the profits generated under the old system. The 23% repatriation tax is a compromise between the new rate of effectively 0% and the old rate of 39%. This BTW happens to be very close to the OECD, the developed world's, average tax rate of 24%.
Edit: As was astutely pointed out below the US only pays additional taxes to the US if their US tax bill was higher than their German one. And they paid the difference between to two to the US.
[0] - https://news.ycombinator.com/item?id=11430290
[1] - https://news.ycombinator.com/item?id=11429859