Yes, that is correct but since the US had until recently the highest corporate tax in the OECD, the US corporation will would almost always pay more taxes on German income than a German corporation would on German it’s German income. Giving the US corporation a systematic disadvantage unless they kept the money out of the US. But all this has now changed.

> What is little known about this tax bill

> 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?

It passed, but there are parts of the bill that only last ten years (those applying to personal/small business taxes), and then those tax rules revert to the previous version after ten years unless they are passed again under non-Byrd rules in the Senate. https://www.bloomberg.com/news/articles/2017-11-14/how-the-b...

Which will of course be extended as no government would survive a personal tax increase

A 'personal tax increase' does not have to be across the board. You could e.g. increase the marginal rate for incomes above $1 million, while keeping other rates the same. That would not be politically difficult. Divide et impera.

Which assumes rational government. Our government is controlled by one party and yet we are heading to a government shutdown over immigration. Rational seems far away.

If the opposing party is threatening shutdown of the government then it would seem that the government is not ruled by that single party.

That single party has the majority of both houses of Congress and also the White House, and yet cannot manage to get a majority vote in the Senate because of disagreement within their own party.

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.

It's law: http://thehill.com/sites/default/files/styles/thumb_small_ar...

It's law, as of a few weeks ago. Some provisions will go into effect over the course of this year.

And either way you have to do all the work for both countries' tax systems. Compliance costs are not negligible.

Yes you get a credit for the foreign taxes paid, but even still it's absurdly punitive for being an American corporation.

I would not consider taxes to be “punitive.” Taxes aren’t punishment. They are much more like a membership fee.

I think it's fine to view taxes that way, but we should also realize that to a business taxes are a cost to be minimized. No for-profit business willingly conducts their affairs to maximize taxes.

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.

Many public corporations want to (indirectly) maximize taxes. That's because taxes are levied on profits, and maximizing profits to increase share value is often a good thing.

What's good for America is good for General Motors.

That's been repeated ad nauseum and isn't relevant to this discussion. Parent was replying to someone who said "punitive".

Taxes are very often used as a punishment to modify people's behavior.

A mandatory membership fee.

It's not mandatory, you're free to move to Somalia and renounce your citizenship if you don't like having a government.

- They do have a governament, even if it doesn’t work.

- 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.

If there's a double taxation treaty for corporate income in place. I have no idea, but it's somewhere in https://www.irs.gov/pub/irs-trty/germany.pdf ...

But of course Apple isn't paying no German taxes. They didn't pay taxes on any of this overseas money, and they had the gall to ask for an "repatriation holiday" so they could pay overall zero taxes on that huge heap of money.

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.

Apple paid millions in VAT, income tax for German employees, environmental (packaging) taxes, etc.

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.

Yes, they paid taxes in Germany, France, etc. it’s reported in their financial statements. They’ve already paid 8 or 9% foreign income taxes on their foreign earnings.

Really?

Because those are EU countries and Apple has a tax deal with Ireland in the EU.

Their corporate headquarter is in Ireland. They pay payroll taxes, VAT etc. in each EU member state just like every business has to. They do not, however, have to pay taxes on their corporate earnings in EU countries other than Ireland. That is a central part of "Freedom of Commerce" in the EU. (One of the EU's 4 foundational freedoms.) What Apple has been rightfully accused of is not paying their taxes on corporate earnings in Ireland.

How do you evade sales tax, labor overhead? 9% is a far ways off from the nominal.