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Good article on Apple and taxes (NYT)

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Alan Browne

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May 23, 2013, 8:44:16 PM5/23/13
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https://www.nytimes.com/2013/05/24/business/making-companies-pay-taxes-the-mccain-way.html?pagewanted=2&ref=business

Concludes: " To get anything done, Congress will have to agree that
Senator McCain’s way of looking at taxes is correct, and accept that
giving a tax break to one person or company must mean forcing others to
pay more than they otherwise would. "


--
"A Canadian is someone who knows how to have sex in a canoe."
-Pierre Berton

JF Mezei

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May 23, 2013, 10:19:41 PM5/23/13
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On 13-05-23 20:44, Alan Browne wrote:
>
> https://www.nytimes.com/2013/05/24/business/making-companies-pay-taxes-the-mccain-way.html?pagewanted=2&ref=business



What is mising from the discussion here are the benefits to the american
economy if money earned overseas is patriated to the USA instead of left
in other countries.

The issue spans more than just taxes the USA govt can collect. Consider
the "quantitative easing" to help spur the economy if Apple were allowed
to bring in tax free 100 billion bucks.


Message has been deleted

JF Mezei

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May 23, 2013, 10:55:04 PM5/23/13
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On 13-05-23 22:35, Michelle Steiner wrote:

> It all depends on what Apple does with the money.

No matter whatr Apple does with it, it is 100 billion that is added to
the US monetary mass. If deposited in a bank, there is the multiplier
effect that allows that bank to make loans etc.

When Apple borrows money to pay for a dividend, it reduces the amounts
banks will lend to other businesses.


If Apple uses that cash to pay dividends, that money goes to
indiciduals and investors and pension plans and is then used to
stimulate the economy.

For the USA, they would rather its multinationals patriate profits made
overseas. (and should provide incentives instead of dis-incentives).

However, from a "good global corporate citizen" point of view,
multinationals are expected to invest in countries where they make
profits. So if Apple-France makes oodles of profits, one would expect
Apple-France to invest to develop some software/hardware development in
France to stimulate the economy in France.


Apple has a very centralised product development perspective. Google is
more decentralised and has software development in different areas of
the world. (Although I believe Apple has localisation done in varius
countries for software translations etc).

I do not know that there is a single anwers to this. But in a global
econo,y, countries need to compete to attract capital/jobs. And if the
USA wants to get jobs back into the USA, it needs to compete against
countries such as China and Ireland.

When you look at aircraft, states and cities compete like mad to get
Boeing to select their city/state for an assembly plant. They not only
waive taxes, but provide subsidies.

And here, we have senators trying to scold Apple instead of asking "what
can we do to get you to bring that money into the USA and help our
economy ?"


bi...@mix.com

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May 24, 2013, 1:58:45 AM5/24/13
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In comp.sys.mac.system JF Mezei <jfmezei...@vaxination.ca> wrote:

> Apple has a very centralised product development perspective. Google is
> more decentralised and has software development in different areas of
> the world.

Based on responses to bug reports, Apple has people in India working
on their software. I'd be surprised if that's the only other (besides
the USA) country, too.

Billy Y..
--
sub #'9+1 ,r0 ; convert ascii byte
add #9.+1 ,r0 ; to an integer
bcc 20$ ; not a number

Barry Margolin

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May 24, 2013, 4:45:39 AM5/24/13
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In article <519ed689$0$26941$c3e8da3$3388...@news.astraweb.com>,
JF Mezei <jfmezei...@vaxination.ca> wrote:

> On 13-05-23 22:35, Michelle Steiner wrote:
>
> > It all depends on what Apple does with the money.
>
> No matter whatr Apple does with it, it is 100 billion that is added to
> the US monetary mass. If deposited in a bank, there is the multiplier
> effect that allows that bank to make loans etc.

One of the stories I heard this week on NPR said that one of the "tax
shelter islands" that many companies use is Manhattan. A foreign
subsidiary can deposit their money in a US bank. It's not taxed by the
US because it belongs to a foreign company and isn't being used to fund
US operations.

But the banks can use it to make loans, etc. The story ended by saying
that although this bolsters the US economy, it's not enough to make up
for the lost tax revenue.

--
Barry Margolin, bar...@alum.mit.edu
Arlington, MA
*** PLEASE post questions in newsgroups, not directly to me ***

Rod Speed

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May 24, 2013, 6:00:30 AM5/24/13
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"JF Mezei" <jfmezei...@vaxination.ca> wrote in message
news:519ece3e$0$64325$c3e8da3$5e5e...@news.astraweb.com...
What matters is where they spend it, not where they keep it.

Rod Speed

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May 24, 2013, 6:17:50 AM5/24/13
to
JF Mezei <jfmezei...@vaxination.ca> wrote
> Michelle Steiner wrote

>> It all depends on what Apple does with the money.

> No matter whatr Apple does with it, it is 100
> billion that is added to the US monetary mass.

Nothing like what Bernanke 'prints'

> If deposited in a bank,

Apple is very unlikely to do that with it.

> there is the multiplier effect that allows that bank to make loans etc.

Only if they do that with it.

> When Apple borrows money to pay for a dividend,

It doesn't do that when it has that sort of surplus cash.

> it reduces the amounts banks will lend to other businesses.

> If Apple uses that cash to pay dividends, that money
> goes to indiciduals and investors and pension plans
> and is then used to stimulate the economy.

That happens regardless of where they keep the surplus
cash that they choose not to distribute as dividends.

> For the USA, they would rather its multinationals
> patriate profits made overseas.

Corse they would, but they arent likely to
deliberately not tax that money so that happens.

> (and should provide incentives instead of dis-incentives).

Not even possible without choosing to not tax them on that money.

> However, from a "good global corporate citizen" point of view,
> multinationals are expected to invest in countries where they
> make profits.

And in the real world they invest where they get the best tax treatment
instead.

> So if Apple-France makes oodles of profits, one would expect
> Apple-France to invest to develop some software/hardware
> development in France to stimulate the economy in France.

You can expect anything you like. Successful multinationals
do the development where it can be done most cheaply and
still get done as well as where else it can be done instead.

> Apple has a very centralised product development perspective.

And that has worked out very well for them with some of the
best products available and driving quite a bit of the market.

> Google is more decentralised and has software
> development in different areas of the world.

And hasn't done anything like as well with hardware products particularly.

Rather better than Apple in some other areas like mapping tho.

But not with OSs.

> (Although I believe Apple has localisation done
> in varius countries for software translations etc).

> I do not know that there is a single anwers to this.

Corse there isnt. If there was someone would have found it by now.

> But in a global econo,y, countries need to compete to attract
> capital/jobs.

And some compete very aggressively indeed
using the taxes they impose, like Ireland.

> And if the USA wants to get jobs back into the USA,

The USA doesn't have a problem with jobs in the USA.

The unemployment rate bottomed at 4.x% with an immense
legal and illegal immigration rate and the participation rate,
the percentage of the workforce that chooses to work, at an
all time historic high, just before the clowns were allowed to
completely implode much of the world financial system, AGAIN.

> it needs to compete against countries such as China and Ireland.

Not even possible to do that with China with the manufacturing
of physical goods. The labor costs are so radically out of line and
will be for the foreseeable future too.

Its unlikely that the US will ever offer anything like the tax
treatment that Ireland has chosen to go for, and you can
make a case that it would be mad for the US to do that too.

> When you look at aircraft, states and cities compete like mad
> to get Boeing to select their city/state for an assembly plant.

But there was no need for the federal govt to offer the same
tax incentives that Ireland chose to have to get Boeing to stay
in the country.

> They not only waive taxes, but provide subsidies.

> And here, we have senators trying to scold Apple

Because both Apple and Google choose to avoid
the taxes that the law requires them to pay.

> instead of asking "what can we do to get you to bring
> that money into the USA and help our economy ?"

Because the answer to that is obvious. There is nothing
that the US can do that will ever get Apple to make its
products in the US again, because labor costs are so
much lower in places like China.

They do still do most of the R&D in the US, because the labor
costs aren't as important with that part of their operation.

Michael Eyd

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May 24, 2013, 6:34:55 AM5/24/13
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Am 24.05.2013 12:17, schrieb Rod Speed:
> JF Mezei <jfmezei...@vaxination.ca> wrote
>> Michelle Steiner wrote

>> And here, we have senators trying to scold Apple
>
> Because both Apple and Google choose to avoid
> the taxes that the law requires them to pay.

That's (for all I know) just plainly wrong. They (and most probably all
the other large corporations all over the world) just choose to follow
the law by the letters, while still combining the different laws (in
different countries) to their advantage. They save on taxes *by obeying
to the law*, not by avoiding the law.

It's not their fault that the taxation laws open those loopholes (some
are certainly there on purpose, some just coincidentally), that's the
job of the politicians.

Actually, if they didn't do it this way, there would likely be
investors, stock-holders, ... complaining about not enough left on the
bottomline - and it might be hard (e.g. in court) to defend against this
claim...

>> instead of asking "what can we do to get you to bring
>> that money into the USA and help our economy ?"
>
> Because the answer to that is obvious. There is nothing
> that the US can do that will ever get Apple to make its
> products in the US again, because labor costs are so
> much lower in places like China.

Interestingly, Apple has announced to start (again) the production of
one line of Macs in the US. Doesn't quite fit to your statement, does
it? ;-)

Kurt Ullman

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May 24, 2013, 8:47:00 AM5/24/13
to
In article <michelle-77C2C7...@news.eternal-september.org>,
Michelle Steiner <mich...@michelle.org> wrote:

> In article <519ece3e$0$64325$c3e8da3$5e5e...@news.astraweb.com>,
> JF Mezei <jfmezei...@vaxination.ca> wrote:
>
> > The issue spans more than just taxes the USA govt can collect. Consider
> > the "quantitative easing" to help spur the economy if Apple were allowed
> > to bring in tax free 100 billion bucks.
>
> It all depends on what Apple does with the money.

And since Apple management still has an aversion to spending money
that is at least as great as my depression-era relatives....
--
America is at that awkward stage. It's too late
to work within the system, but too early to shoot
the bastards."-- Claire Wolfe

Kurt Ullman

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May 24, 2013, 8:54:44 AM5/24/13
to
In article <barmar-1EC4DD....@news.eternal-september.org>,
Barry Margolin <bar...@alum.mit.edu> wrote:

>
> One of the stories I heard this week on NPR said that one of the "tax
> shelter islands" that many companies use is Manhattan. A foreign
> subsidiary can deposit their money in a US bank. It's not taxed by the
> US because it belongs to a foreign company and isn't being used to fund
> US operations.
>
> But the banks can use it to make loans, etc. The story ended by saying
> that although this bolsters the US economy, it's not enough to make up
> for the lost tax revenue.

What lost tax revenue? If it belongs to a foreign company and isn't
being used to fund US operations I don't see how the US would have any
claim on it anyway. Wouldn't there be ADDITIONAL tax revenue from the
money the US bank made on fees, etc., from the deposit?

nospam

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May 24, 2013, 9:03:13 AM5/24/13
to
In article <knmvil$l0d$1...@reader1.panix.com>, <bi...@MIX.COM> wrote:

> > Apple has a very centralised product development perspective. Google is
> > more decentralised and has software development in different areas of
> > the world.
>
> Based on responses to bug reports, Apple has people in India working
> on their software. I'd be surprised if that's the only other (besides
> the USA) country, too.

what bug reports and what responses?

because apple's engineering is done in cupertino. they don't offshore
development. it even says so on the box, 'designed by apple in
california.'

nospam

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May 24, 2013, 9:03:16 AM5/24/13
to
In article <b08t4a...@mid.individual.net>, Rod Speed
<rod.sp...@gmail.com> wrote:

> > And here, we have senators trying to scold Apple
>
> Because both Apple and Google choose to avoid
> the taxes that the law requires them to pay.

they use legal ways to minimize how much tax they are required to pay,
just as ordinary taxpayers do.

> > instead of asking "what can we do to get you to bring
> > that money into the USA and help our economy ?"
>
> Because the answer to that is obvious. There is nothing
> that the US can do that will ever get Apple to make its
> products in the US again, because labor costs are so
> much lower in places like China.

except that apple makes a lot of stuff in the usa, including a mac
that's about to be released along with many parts for a variety of
products.

Kurt Ullman

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May 24, 2013, 9:06:59 AM5/24/13
to
In article <b08t4a...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:


> > When Apple borrows money to pay for a dividend,
>
> It doesn't do that when it has that sort of surplus cash.

Actually they just did. (And it isn't terribly unusual way to do things
any more).



> Not even possible to do that with China with the manufacturing
> of physical goods. The labor costs are so radically out of line and
> will be for the foreseeable future too.
Especially for high value added stuff, that is not necessarily the
case. Whirlpool (and heck even Apple) and others have announced they are
brining back some of the work. China is no more immune from supply
demand things as any place else and wages have been driven up (albeit
from a low base) there. Add in govermental interference, cost of
shipping, the Chines playing games with currency, industrial espionage
and general headaches and the Americans are looking better and better.


> Because both Apple and Google choose to avoid
> the taxes that the law requires them to pay.

Nope not in the least. They very carefully use the term tax avoidance
because that is entirely legal. It is tax evasion when they don't pay
what the laws requires them to pay.
Even though some Senators are using avoidance in a way that implies
otherwise, it well established in the US law that avoidance of taxes is
perfectly legal.
I commend to you the words of Judge Learned Hand:
"Anyone may arrange his affairs so that his taxes shall be as low as
possible; he is not bound to choose that pattern which best pays the
treasury. There is not even a patriotic duty to increase one's taxes.
Over and over again the Courts have said that there is nothing sinister
in so arranging affairs as to keep taxes as low as possible. Everyone
does it, rich and poor alike and all do right, for nobody owes any
public duty to pay more than the law demands."

Unless, apparently it offends the sensitivities of some
CongressCritters.

>
> > instead of asking "what can we do to get you to bring
> > that money into the USA and help our economy ?"
>
> Because the answer to that is obvious. There is nothing
> that the US can do that will ever get Apple to make its
> products in the US again, because labor costs are so
> much lower in places like China.

I guess Mr. Cook never got that memo.
http://www.huffingtonpost.com/2012/12/06/apple-manufacturing-usa-macs_n_2
249613.html
Message has been deleted
Message has been deleted

nospam

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May 24, 2013, 10:09:13 AM5/24/13
to
In article <michelle-56A80A...@news.eternal-september.org>,
Michelle Steiner <mich...@michelle.org> wrote:

> > > Because the answer to that is obvious. There is nothing
> > > that the US can do that will ever get Apple to make its
> > > products in the US again, because labor costs are so
> > > much lower in places like China.
> >
> > I guess Mr. Cook never got that memo.
> > http://www.huffingtonpost.com/2012/12/06/apple-manufacturing-usa-macs_n_2
> > 249613.html
>
> I wonder whether that's merely a PR thing�accepting the increase in
> production costs in return for the ensuing PR benefits. I'm not saying
> that it is; I'm wondering whether it is.

apple said that a lot of components are made in the usa, which would
then need to be shipped to china for assembly. manufacturing everything
in the usa streamlines it.

you can be sure they did't do it because they want to spend more money
than they have to.

Kurt Ullman

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May 24, 2013, 10:54:53 AM5/24/13
to
In article <michelle-56A80A...@news.eternal-september.org>,
Michelle Steiner <mich...@michelle.org> wrote:


> I wonder whether that's merely a PR thing�accepting the increase in
> production costs in return for the ensuing PR benefits. I'm not saying
> that it is; I'm wondering whether it is.

There is a fairly long list of companies that are either pulling
production back from overseas (Whirlpool in Kentucky for instance) or
putting new lines in here instead of elsewhere. Not a flood by any
means, but still a shift. I've got a full (albeit year old) list of some
of these companies floating around here somehwere. If I can find I'll
add in some others.

News

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May 24, 2013, 10:57:46 AM5/24/13
to
On 5/24/2013 10:54 AM, Kurt Ullman wrote:
> In article <michelle-56A80A...@news.eternal-september.org>,
> Michelle Steiner <mich...@michelle.org> wrote:
>
>
>> I wonder whether that's merely a PR thing�accepting the increase in
>> production costs in return for the ensuing PR benefits. I'm not saying
>> that it is; I'm wondering whether it is.
>
> There is a fairly long list of companies that are either pulling
> production back from overseas (Whirlpool in Kentucky for instance) or
> putting new lines in here instead of elsewhere. Not a flood by any
> means, but still a shift. I've got a full (albeit year old) list of some
> of these companies floating around here somehwere. If I can find I'll
> add in some others.
>


More a global logistics cost optimization issue than not.

bi...@mix.com

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May 24, 2013, 11:06:26 AM5/24/13
to
In comp.sys.mac.system nospam <nos...@nospam.invalid> wrote, quoting me:

> > Based on responses to bug reports, Apple has people in India working
> > on their software. I'd be surprised if that's the only other (besides
> > the USA) country, too.
>
> what bug reports and what responses?

If you had ever reported anything worth a response, you'd know they
all contain this -

| *****************************************************************
| THE INFORMATION CONTAINED IN THIS MESSAGE IS UNDER NON-DISCLOSURE
| *****************************************************************

Hopefully I won't catch hell for disclosing that. Heh.

> because apple's engineering is done in cupertino. they don't offshore
> development. it even says so on the box, 'designed by apple in
> california.'

You base your conclusion on "it even says so on the box?"
Message has been deleted

nospam

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May 24, 2013, 11:39:17 AM5/24/13
to
In article <knnvli$nbi$2...@reader1.panix.com>, <bi...@MIX.COM> wrote:

> > > Based on responses to bug reports, Apple has people in India working
> > > on their software. I'd be surprised if that's the only other (besides
> > > the USA) country, too.
> >
> > what bug reports and what responses?
>
> If you had ever reported anything worth a response, you'd know they
> all contain this -
>
> | *****************************************************************
> | THE INFORMATION CONTAINED IN THIS MESSAGE IS UNDER NON-DISCLOSURE
> | *****************************************************************
>
> Hopefully I won't catch hell for disclosing that. Heh.

what about the response tells you apple offshores development? is it
written in broken english?

> > because apple's engineering is done in cupertino. they don't offshore
> > development. it even says so on the box, 'designed by apple in
> > california.'
>
> You base your conclusion on "it even says so on the box?"

apple has stated they do their r&d in california, which is *why* they
say that on the box.

they also decided against a call center in india because customers
don't like that.

Doc O'Leary

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May 24, 2013, 12:06:44 PM5/24/13
to
> In article <519ed689$0$26941$c3e8da3$3388...@news.astraweb.com>,
> JF Mezei <jfmezei...@vaxination.ca> wrote:
>
> > On 13-05-23 22:35, Michelle Steiner wrote:
> >
> > > It all depends on what Apple does with the money.
> >
> > No matter whatr Apple does with it, it is 100 billion that is added to
> > the US monetary mass. If deposited in a bank, there is the multiplier
> > effect that allows that bank to make loans etc.
>
> ...
>
> But the banks can use it to make loans, etc. The story ended by saying
> that although this bolsters the US economy, it's not enough to make up
> for the lost tax revenue.

Real value is no longer needed to make loans. Banks just print up money
out of thin air when they want to borrow it out. That's why you can't
find a savings account that pays a decent rate of interest, and
sometimes even the interest rate on the the loans *themselves* is less
than inflation. It's madness, but people bury their heads in the sand
the same way they do when they can buy things made in [insert foreign
economy here] to save a few cents yet still wonder where all the local
jobs/money/value went.

As far as this Apple kerfuffle is concerned, my understanding is that
the main reason they're a target is that they're using (some of) the
same loopholes that other corporations abuse, but they're doing it
without having lined the pockets of the politicians. Apple doesn't
lobby as much as some corrupt individuals would like; people were bought
by one company to pass a bad law, and now they think they can collect
from every company that benefits from it. Apple's best defense here, at
least in the eyes of the public, would be to call the lawmakers on the
bullshit laws they made.

There are still problems with wealth accumulation, by Apple and others,
when it comes to keeping a functioning world economy. It's all a big
mess of people denying reality as they exploit resources. Even if they
took all of Apple's profits as "taxes", it wouldn't make a sustainable
system. Until some actual science is introduced into the process, it
remains fundamentally broken in the long term. Of course, given some of
the battles I've had with the App Store review process, science isn't
exactly overabundant at Apple, either.

--
iPhone apps that matter: http://appstore.subsume.com/
My personal UDP list: 127.0.0.1, localhost, googlegroups.com, theremailer.net,
and probably your server, too.
Message has been deleted

bi...@mix.com

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May 24, 2013, 1:50:49 PM5/24/13
to
In comp.sys.mac.system Lewis <g.k...@gmail.com.dontsendmecopies> wrote:

> >> because apple's engineering is done in cupertino. they don't offshore
> >> development. it even says so on the box, 'designed by apple in
> >> california.'
>
> > You base your conclusion on "it even says so on the box?"
>
> Yes, since there are laws about what you can say on the box.

Which laws are those? Care to be specific?

Regardless, does it also say, for example, "Made in China?"

Or, for those still struggling to comprehend simple English,
perhaps "Assembled in China?"

Rod Speed

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May 24, 2013, 3:46:21 PM5/24/13
to
Michael Eyd <inv...@eyd.de> wrote
> Rod Speed wrote
>> JF Mezei <jfmezei...@vaxination.ca> wrote
>>> Michelle Steiner wrote

>>> And here, we have senators trying to scold Apple

>> Because both Apple and Google choose to avoid
>> the taxes that the law requires them to pay.

> That's (for all I know) just plainly wrong.

You are just plain wrong.

> They (and most probably all the other large corporations all
> over the world) just choose to follow the law by the letters,
> while still combining the different laws (in different countries)
> to their advantage. They save on taxes *by obeying
> to the law*, not by avoiding the law.

They flout the law by deliberately moving the the profits
they make to places where they are not taxed on that profit.

Google does that by lying thru their teeth
on where the intellectual property is owned.

Do you SERIOUSLY believe that the bulk of News's
operations are actually in the Bahamas ?

Of course they aren't.

> It's not their fault that the taxation laws open those loopholes
> (some are certainly there on purpose, some just coincidentally),
> that's the job of the politicians.

Google and Apple don't avoid paying the tax they
are legally required to pay by using loopholes.

> Actually, if they didn't do it this way, there would
> likely be investors, stock-holders, ... complaining
> about not enough left on the bottomline

Even sillier with Apple and Google.

> - and it might be hard (e.g. in court) to defend against this claim...

Bullshit.

>>> instead of asking "what can we do to get you to bring
>>> that money into the USA and help our economy ?"

>> Because the answer to that is obvious. There is nothing
>> that the US can do that will ever get Apple to make its
>> products in the US again, because labor costs are so
>> much lower in places like China.

> Interestingly, Apple has announced to start (again)
> the production of one line of Macs in the US.

Just another PR exercise.

> Doesn't quite fit to your statement, does it? ;-)

Get back to us when they do that with the iphone and ipad.

Rod Speed

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May 24, 2013, 3:51:08 PM5/24/13
to
nospam <nos...@nospam.invalid> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>> And here, we have senators trying to scold Apple

>> Because both Apple and Google choose to avoid
>> the taxes that the law requires them to pay.

> they use legal ways to minimize how
> much tax they are required to pay,

That's very arguable indeed when operations
like google claim that the intellectual property
they own is owned outside the US and that
they have to pay foreign operations of theirs
to use that intellectual property.

> just as ordinary taxpayers do.

Nothing like ordinary taxpayers do in fact.

>>> instead of asking "what can we do to get you to bring
>>> that money into the USA and help our economy ?"

>> Because the answer to that is obvious. There is nothing
>> that the US can do that will ever get Apple to make its
>> products in the US again, because labor costs are so
>> much lower in places like China.

> except that apple makes a lot of stuff in the usa,

It has a hell of a lot more stuff manufactured for them outside the USA.

> including a mac that's about to be released
> along with many parts for a variety of products.

Get back to us when the manufacture of ipads and iphones is moved to the US.

nospam

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May 24, 2013, 4:14:56 PM5/24/13
to
In article <b09unc...@mid.individual.net>, Rod Speed
<rod.sp...@gmail.com> wrote:

> > just as ordinary taxpayers do.
>
> Nothing like ordinary taxpayers do in fact.

they use different forms, but the concept is identical. nobody wants to
pay more taxes than they legally owe, whether it's an individual or a
corporation.

minimizing what you own by abiding by existing tax law is legal.
circumventing it is not. there's a very clear difference.

> >>> instead of asking "what can we do to get you to bring
> >>> that money into the USA and help our economy ?"
>
> >> Because the answer to that is obvious. There is nothing
> >> that the US can do that will ever get Apple to make its
> >> products in the US again, because labor costs are so
> >> much lower in places like China.
>
> > except that apple makes a lot of stuff in the usa,
>
> It has a hell of a lot more stuff manufactured for them outside the USA.

so what? the fact is they are moving some production to the usa, which
you said would never happen. it's *happening*.

> > including a mac that's about to be released
> > along with many parts for a variety of products.
>
> Get back to us when the manufacture of ipads and iphones is moved to the US.

moving the goalposts again. nobody said they were going to move all of
it here.
Message has been deleted

JF Mezei

unread,
May 24, 2013, 4:24:12 PM5/24/13
to
On 13-05-24 15:46, Rod Speed wrote:

> They flout the law by deliberately moving the the profits
> they make to places where they are not taxed on that profit.

Not true, Apple France pays taxes to french government on its profits.
But instead of sending profits to Apple USA where they would be taxed
AGAIN, they are sent to Apple Ireland where the cash can be parked tax free.



Alan Browne

unread,
May 24, 2013, 4:31:43 PM5/24/13
to
On 2013.05.23 22:19 , JF Mezei wrote:
> On 13-05-23 20:44, Alan Browne wrote:
>>
>> https://www.nytimes.com/2013/05/24/business/making-companies-pay-taxes-the-mccain-way.html?pagewanted=2&ref=business
>
>
>
> What is mising

What should be missing is you insisting on re-writing what you've
written so often.


--
"A Canadian is someone who knows how to have sex in a canoe."
-Pierre Berton

Kurt Ullman

unread,
May 24, 2013, 4:34:45 PM5/24/13
to
In article <b09unc...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:

> nospam <nos...@nospam.invalid> wrote
> > Rod Speed <rod.sp...@gmail.com> wrote
>
> >>> And here, we have senators trying to scold Apple
>
> >> Because both Apple and Google choose to avoid
> >> the taxes that the law requires them to pay.
>
> > they use legal ways to minimize how
> > much tax they are required to pay,
>
> That's very arguable indeed when operations
> like google claim that the intellectual property
> they own is owned outside the US and that
> they have to pay foreign operations of theirs
> to use that intellectual property.
But they do, and perfectly legally.


>
> > just as ordinary taxpayers do.
>
> Nothing like ordinary taxpayers do in fact.
What, so you don't give money to some exempt entity to lessen your
tax liability? You don't claim the deduction for your mortgage or you
don't take your full legal standard deduction if that is all you have
available?

Rod Speed

unread,
May 24, 2013, 6:30:57 PM5/24/13
to
Kurt Ullman <kurtu...@yahoo.com> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>> When Apple borrows money to pay for a dividend,

>> It doesn't do that when it has that sort of surplus cash.

> Actually they just did.

What they ACTUALLY just did is avoid repatriating
the cash they have outside the country back to the US
where they would have to pay 35% tax on that money.

Its just another tax rort in fact.

> (And it isn't terribly unusual way to do things any more).

It is in fact so unusual that it gets commented on in the media.

>> Not even possible to do that with China with the manufacturing
>> of physical goods. The labor costs are so radically out of line and
>> will be for the foreseeable future too.

> Especially for high value added stuff, that is not necessarily
> the case. Whirlpool (and heck even Apple) and others have
> announced they are brining back some of the work.

Very little of the work in fact in the case of Apple.

> China is no more immune from supply demand things as any place
> else and wages have been driven up (albeit from a low base) there.

To nothing like the level they are in the US.

> Add in govermental interference, cost of shipping,

Peanuts in the cost of say an iphone.

> the Chines playing games with currency,

ALL they are doing is keeping the yuan locked to the USD.

> industrial espionage and general headaches and
> the Americans are looking better and better.

No. Apple still gets the absolute vast bulk of
what they get made for them done in China.

>> Because both Apple and Google choose to avoid
>> the taxes that the law requires them to pay.

> Nope not in the least.

Wrong.

> They very carefully use the term tax
> avoidance because that is entirely legal.

Its bullshit to claim that the bulk of what News is about is
actually in the Bahamas, that is a bare faced taxed fraud.

> It is tax evasion when they don't pay what the laws requires them to pay.

And that is precisely what they are doing when they deliberately
choose not to repatriate the money they earn out of the country to
the US where they would have to pay a 35% tax on that if they did.

> Even though some Senators are using avoidance in a
> way that implies otherwise, it well established in the
> US law that avoidance of taxes is perfectly legal.

Never said it wasn�t legal. Its clearly avoiding the taxes
the law says they have to pay, most obviously with all
that foreign cash they choose to keep out of the US.

> I commend to you the words of Judge Learned Hand:
> "Anyone may arrange his affairs so that his taxes shall be as low as
> possible; he is not bound to choose that pattern which best pays the
> treasury. There is not even a patriotic duty to increase one's taxes.
> Over and over again the Courts have said that there is nothing sinister
> in so arranging affairs as to keep taxes as low as possible. Everyone
> does it, rich and poor alike and all do right, for nobody owes any
> public duty to pay more than the law demands."

Just the sort of mindless bullshit that only a judge could spew.

> Unless, apparently it offends the sensitivities of some CongressCritters.

It offends the sensibilitys of US taxpayers too.

>>> instead of asking "what can we do to get you to bring
>>> that money into the USA and help our economy ?"

>> Because the answer to that is obvious. There is nothing
>> that the US can do that will ever get Apple to make its
>> products in the US again, because labor costs are so
>> much lower in places like China.

> I guess Mr. Cook never got that memo.
> http://www.huffingtonpost.com/2012/12/06/apple-manufacturing-usa-macs_n_2249613.html

Get back to us when they move all the manufacturing of iphones, ipads, ipods
back to the US.

Taint gunna happen.

Rod Speed

unread,
May 24, 2013, 6:35:15 PM5/24/13
to
Kurt Ullman <kurtu...@yahoo.com> wrote
> Michelle Steiner <mich...@michelle.org> wrote

>> I wonder whether that's merely a PR thing�accepting the
>> increase in production costs in return for the ensuing PR
>> benefits. I'm not saying that it is; I'm wondering whether it is.

> There is a fairly long list of companies that are either pulling
> production back from overseas (Whirlpool in Kentucky for
> instance) or putting new lines in here instead of elsewhere.

There is in fact a MUCH bigger list of those who aren't doing that.

And even Apple is only doing that with a microscopic
subset of what they get manufactured in total.

> Not a flood by any means, but still a shift.

Not when you count the stuff that is still seeing
the manufacturing being moved offshore.

> I've got a full (albeit year old) list of some of these companies
> floating around here somehwere. If I can find I'll add in some others.

Try comparing it with the list of what gets sold in Walmart etc which isnt.

Jolly Roger

unread,
May 24, 2013, 6:44:20 PM5/24/13
to
In article <b0a8b4...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:

> Kurt Ullman <kurtu...@yahoo.com> wrote
> > Michelle Steiner <mich...@michelle.org> wrote
>
> >> I wonder whether that's merely a PR thing�accepting the
> >> increase in production costs in return for the ensuing PR
> >> benefits. I'm not saying that it is; I'm wondering whether it is.
>
> > There is a fairly long list of companies that are either pulling
> > production back from overseas (Whirlpool in Kentucky for
> > instance) or putting new lines in here instead of elsewhere.
>
> There is in fact a MUCH bigger list of those who aren't doing that.
>
> And even Apple is only doing that with a microscopic
> subset of what they get manufactured in total.
>
> > Not a flood by any means, but still a shift.
>
> Not when you count the stuff that is still seeing
> the manufacturing being moved offshore.
>
> > I've got a full (albeit year old) list of some of these companies
> > floating around here somehwere. If I can find I'll add in some others.
>
> Try comparing it with the list of what gets sold in Walmart etc which isnt.

Better than nothing.

--
Send responses to the relevant news group rather than email to me.
E-mail sent to this address may be devoured by my very hungry SPAM
filter. Due to Google's refusal to prevent spammers from posting
messages through their servers, I often ignore posts from Google
Groups. Use a real news client if you want me to see your posts.

JR

Rod Speed

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May 24, 2013, 6:48:17 PM5/24/13
to
Doc O'Leary <drolear...@2q2013.subsume.com> wrote
> Barry Margolin <bar...@alum.mit.edu> wrote
>> JF Mezei <jfmezei...@vaxination.ca> wrote
>>> Michelle Steiner wrote

>>>> It all depends on what Apple does with the money.

>>> No matter whatr Apple does with it, it is 100 billion that is
>>> added to the US monetary mass. If deposited in a bank, there
>>> is the multiplier effect that allows that bank to make loans etc.

>> But the banks can use it to make loans, etc. The story ended
>> by saying that although this bolsters the US economy, it's
>> not enough to make up for the lost tax revenue.

> Real value is no longer needed to make loans. Banks just print
> up money out of thin air when they want to borrow it out.

Even US banks don�t get to do that.

> That's why you can't find a savings account that pays a decent rate of
> interest,

No, that is because the Fed has driven interest rates
to the lowest they have been for a very long time.

> and sometimes even the interest rate on the
> the loans *themselves* is less than inflation.

Because the Fed has driven interest rates to
the lowest they have been for a very long time.

> It's madness,

No, its what has avoided another great depression or worse.

> but people bury their heads in the sand the same
> way they do when they can buy things made in
> [insert foreign economy here] to save a few cents

They save a hell of a lot more than just a few cents.

And I bet that what you are using to post on
wasn�t made in the US unless its an antique.

> yet still wonder where all the local jobs/money/value went.

The US unemployment rate bottomed at 4.x% with an immense
legal and illegal immigration rate and the participation rate, the
percentage of the workforce that chooses to work, at an all time
historic high, just before the clowns were allowed to completely
implode much of the world financial system, AGAIN.

> As far as this Apple kerfuffle is concerned, my understanding
> is that the main reason they're a target is that they're using
> (some of) the same loopholes that other corporations abuse,

They arent loopholes. They are avoiding repatriating the money
they earn out of the country because if they did move it back
to the US, they would have to pay 35% tax on that.

> but they're doing it without having lined the pockets of the politicians.

Even sillier.

> Apple doesn't lobby as much as some corrupt individuals would like;

They don�t need to lobby, they are raking it in without doing that.

> people were bought by one company to pass a bad law, and now
> they think they can collect from every company that benefits from
> it. Apple's best defense here, at least in the eyes of the public,
> would be to call the lawmakers on the bullshit laws they made.

Nothing bullshit about the laws that require Apple to
pay 35% tax on the money they earn out of the country.

> There are still problems with wealth accumulation, by Apple and
> others, when it comes to keeping a functioning world economy.
> It's all a big mess of people denying reality as they exploit resources.
> Even if they took all of Apple's profits as "taxes", it wouldn't make
> a sustainable system. Until some actual science is introduced into
> the process, it remains fundamentally broken in the long term.

Not even possible to apply science to tax law.

> Of course, given some of the battles I've had with the App Store
> review process, science isn't exactly overabundant at Apple, either.

Or in politics in spades.

Kurt Ullman

unread,
May 24, 2013, 6:51:58 PM5/24/13
to
In article <b0a831...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:

>
> What they ACTUALLY just did is avoid repatriating
> the cash they have outside the country back to the US
> where they would have to pay 35% tax on that money.
>
> Its just another tax rort in fact.
Tax rort?




> >> Because both Apple and Google choose to avoid
> >> the taxes that the law requires them to pay.
>
> > Nope not in the least.
>
> Wrong.
Even the Congress critters aren't saying they did anything illegal.
The very carefully use the term avoidance since that has legal meaning
that is very different from evasion (this one being the illegal part).

> > It is tax evasion when they don't pay what the laws requires them to pay.
You have any evidence of that, then bring it on. Nobody has been
raided by the IRS or Federal Marshalls for underpayment of taxes.

>
> And that is precisely what they are doing when they deliberately
> choose not to repatriate the money they earn out of the country to
> the US where they would have to pay a 35% tax on that if they did.
Not according to current tax laws.

>
> > Even though some Senators are using avoidance in a
> > way that implies otherwise, it well established in the
> > US law that avoidance of taxes is perfectly legal.
>
> Never said it wasn�t legal. Its clearly avoiding the taxes
> the law says they have to pay, most obviously with all
> that foreign cash they choose to keep out of the US.
If you aren't paying taxed the law says they **have** to pay, that
is indeed illegal. Otherwise they wouldn't have to pay it.

>
> > I commend to you the words of Judge Learned Hand:
> > "Anyone may arrange his affairs so that his taxes shall be as low as
> > possible; he is not bound to choose that pattern which best pays the
> > treasury. There is not even a patriotic duty to increase one's taxes.
> > Over and over again the Courts have said that there is nothing sinister
> > in so arranging affairs as to keep taxes as low as possible. Everyone
> > does it, rich and poor alike and all do right, for nobody owes any
> > public duty to pay more than the law demands."
>
> Just the sort of mindless bullshit that only a judge could spew.

You are kidding right? You aren't really trying to tell me that
people should pay more than they have to under the laws and there is no
right to pay up to what you actually owe but not over, are you?

>
> > Unless, apparently it offends the sensitivities of some CongressCritters.
>
> It offends the sensibilitys of US taxpayers too.
YOUR sensibilities. Obviously not mine and would doubt others on the
list. So, we should base tax policy on what offends you?

>
> Get back to us when they move all the manufacturing of iphones, ipads, ipods
> back to the US.
>
> Taint gunna happen.
Why should they move all iPhones, etc., back to the US. It isn't the
only market. Heck, IIRC, China is the biggest smartphone market now.

Kurt Ullman

unread,
May 24, 2013, 6:55:56 PM5/24/13
to
In article <b0a93h...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:


> > It's madness,
>
> No, its what has avoided another great depression or worse.

For now. We'll see what happens longer term when the Fed tries to
unwind it.

> They arent loopholes. They are avoiding repatriating the money
> they earn out of the country because if they did move it back
> to the US, they would have to pay 35% tax on that.
But they are doing legally. Avoidance is illegal even if it does
offend you.


>
> > people were bought by one company to pass a bad law, and now
> > they think they can collect from every company that benefits from
> > it. Apple's best defense here, at least in the eyes of the public,
> > would be to call the lawmakers on the bullshit laws they made.
>
> Nothing bullshit about the laws that require Apple to
> pay 35% tax on the money they earn out of the country.
But there is NO law that says that until they bring it on shore.
None. Zilch. Nada. Bupkus. etc.

>
> > There are still problems with wealth accumulation, by Apple and
> > others, when it comes to keeping a functioning world economy.
> > It's all a big mess of people denying reality as they exploit resources.
> > Even if they took all of Apple's profits as "taxes", it wouldn't make
> > a sustainable system. Until some actual science is introduced into
> > the process, it remains fundamentally broken in the long term.
>
> Not even possible to apply science to tax law.
The science of economics (okay you may have a point there-grin).

Rod Speed

unread,
May 24, 2013, 7:00:19 PM5/24/13
to
nospam <nos...@nospam.invalid> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>> just as ordinary taxpayers do.

>> Nothing like ordinary taxpayers do in fact.

> they use different forms, but the concept is identical.

It's just not possible for ordinary taxpayers to get away
with claiming that they earned the bulk of their income
in the Bahamas when their work is in the US.

It is possible for an operation like News to do that, so its
nothing like what is possible for an ordinary taxpayer.

> nobody wants to pay more taxes than they legally
> owe, whether it's an individual or a corporation.

Separate matter entirely to how they go about minimising
the tax they pay. What an operation like Apple or Google
does isnt even possible for an ordinary taxpayer to do.

> minimizing what you own by abiding by existing tax law is
> legal. circumventing it is not. there's a very clear difference.

Having fun thrashing that straw man ?

>>>>> instead of asking "what can we do to get you to bring
>>>>> that money into the USA and help our economy ?"

>>>> Because the answer to that is obvious. There is nothing
>>>> that the US can do that will ever get Apple to make its
>>>> products in the US again, because labor costs are so
>>>> much lower in places like China.

>>> except that apple makes a lot of stuff in the usa,

>> It has a hell of a lot more stuff manufactured for them outside the USA.

> so what?

So apple has a hell of a lot more made for them out of the USA.

> the fact is they are moving some production to the usa,

We'll see...

> which you said would never happen. it's *happening*.

Get back to us when they move the manufacturing of
iphones, ipads, ipods, which they manufacture in VASTLY
greater volume than just one Mac line, back to the US.

>>> including a mac that's about to be released
>>> along with many parts for a variety of products.

>> Get back to us when the manufacture of ipads and iphones is moved to the
>> US.

> moving the goalposts again.

You are lying, again.

> nobody said they were going to move all of it here.

In fact they are moving fuck all back to the US.

Rod Speed

unread,
May 24, 2013, 7:02:00 PM5/24/13
to
JF Mezei <jfmezei...@vaxination.ca> wrote
> Rod Speed wrote

>> They flout the law by deliberately moving the the profits
>> they make to places where they are not taxed on that profit.

> Not true,

It is true with Google.

> Apple France pays taxes to french government on its profits.

And US law requires that they pay US tax on those profits too.

> But instead of sending profits to Apple USA where they would be taxed
> AGAIN, they are sent to Apple Ireland where the cash can be parked tax
> free.

And that flouts US tax law.

Rod Speed

unread,
May 24, 2013, 7:05:36 PM5/24/13
to
Kurt Ullman <kurtu...@yahoo.com> wrote
> Rod Speed <rod.sp...@gmail.com> wrote
>> nospam <nos...@nospam.invalid> wrote
>>> Rod Speed <rod.sp...@gmail.com> wrote

>>>>> And here, we have senators trying to scold Apple

>>>> Because both Apple and Google choose to avoid
>>>> the taxes that the law requires them to pay.

>>> they use legal ways to minimize how
>>> much tax they are required to pay,

>> That's very arguable indeed when operations
>> like google claim that the intellectual property
>> they own is owned outside the US and that
>> they have to pay foreign operations of theirs
>> to use that intellectual property.

> But they do,

Only to avoid tax.

> and perfectly legally.

It isnt perfectly legal to claim that google's
intellectual property was developed in that
tax haven. It�s a bare faced lie.

>>> just as ordinary taxpayers do.

>> Nothing like ordinary taxpayers do in fact.

> What, so you don't give money to some
> exempt entity to lessen your tax liability?

That isnt what Apple and Google are doing.

> You don't claim the deduction for your mortgage

That isnt what Apple and Google are doing.

> or you don't take your full legal standard
> deduction if that is all you have available?

That isnt what Apple and Google are doing.


Rod Speed

unread,
May 24, 2013, 7:06:54 PM5/24/13
to


"Jolly Roger" <jolly...@pobox.com> wrote in message
news:jollyroger-20013...@news.individual.net...
> In article <b0a8b4...@mid.individual.net>,
> "Rod Speed" <rod.sp...@gmail.com> wrote:
>
>> Kurt Ullman <kurtu...@yahoo.com> wrote
>> > Michelle Steiner <mich...@michelle.org> wrote
>>
>> >> I wonder whether that's merely a PR thing�accepting the
>> >> increase in production costs in return for the ensuing PR
>> >> benefits. I'm not saying that it is; I'm wondering whether it is.
>>
>> > There is a fairly long list of companies that are either pulling
>> > production back from overseas (Whirlpool in Kentucky for
>> > instance) or putting new lines in here instead of elsewhere.
>>
>> There is in fact a MUCH bigger list of those who aren't doing that.
>>
>> And even Apple is only doing that with a microscopic
>> subset of what they get manufactured in total.
>>
>> > Not a flood by any means, but still a shift.
>>
>> Not when you count the stuff that is still seeing
>> the manufacturing being moved offshore.
>>
>> > I've got a full (albeit year old) list of some of these companies
>> > floating around here somehwere. If I can find I'll add in some others.
>>
>> Try comparing it with the list of what gets sold in Walmart etc which
>> isnt.
>
> Better than nothing.

Remains to be seen if its more the fuck all of nothing.

nospam

unread,
May 24, 2013, 7:09:34 PM5/24/13
to
In article <b0a831...@mid.individual.net>, Rod Speed
<rod.sp...@gmail.com> wrote:

> What they ACTUALLY just did is avoid repatriating
> the cash they have outside the country back to the US
> where they would have to pay 35% tax on that money.

completely legal.

nospam

unread,
May 24, 2013, 7:09:36 PM5/24/13
to
In article <b0a9q3...@mid.individual.net>, Rod Speed
<rod.sp...@gmail.com> wrote:

> >>> just as ordinary taxpayers do.
>
> >> Nothing like ordinary taxpayers do in fact.
>
> > they use different forms, but the concept is identical.
>
> It's just not possible for ordinary taxpayers to get away
> with claiming that they earned the bulk of their income
> in the Bahamas when their work is in the US.

depends how much time they spend there and how much they earn there.

> >>>>> instead of asking "what can we do to get you to bring
> >>>>> that money into the USA and help our economy ?"
>
> >>>> Because the answer to that is obvious. There is nothing
> >>>> that the US can do that will ever get Apple to make its
> >>>> products in the US again, because labor costs are so
> >>>> much lower in places like China.
>
> >>> except that apple makes a lot of stuff in the usa,
>
> >> It has a hell of a lot more stuff manufactured for them outside the USA.
>
> > so what?
>
> So apple has a hell of a lot more made for them out of the USA.

so what?

> > the fact is they are moving some production to the usa,
>
> We'll see...

and that will be in a little over 2 weeks.

> > which you said would never happen. it's *happening*.
>
> Get back to us when they move the manufacturing of
> iphones, ipads, ipods, which they manufacture in VASTLY
> greater volume than just one Mac line, back to the US.

not the issue.

Kurt Ullman

unread,
May 24, 2013, 7:14:15 PM5/24/13
to
In article <b0a9q3...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:

> nospam <nos...@nospam.invalid> wrote
> > Rod Speed <rod.sp...@gmail.com> wrote
>
> >>> just as ordinary taxpayers do.
>
> >> Nothing like ordinary taxpayers do in fact.
>
> > they use different forms, but the concept is identical.
>
> It's just not possible for ordinary taxpayers to get away
> with claiming that they earned the bulk of their income
> in the Bahamas when their work is in the US.
Actually it is. If you meet certain requirements, the IRS allows you
to exclude up to $80,000 of your income from being taxed. You may also
be able to deduct certain amounts you paid for your housing. You can
also deduct some expenses like non-business travel back to the US in
some cases.


> Separate matter entirely to how they go about minimising
> the tax they pay. What an operation like Apple or Google
> does isnt even possible for an ordinary taxpayer to do.

Probably because Corp taxes are different from personal taxes.

o

Rod Speed

unread,
May 24, 2013, 7:16:13 PM5/24/13
to
Kurt Ullman <kurtu...@yahoo.com> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>> What they ACTUALLY just did is avoid repatriating
>> the cash they have outside the country back to the US
>> where they would have to pay 35% tax on that money.

>> Its just another tax rort in fact.

> Tax rort?

http://en.wiktionary.org/wiki/rort?rdfrom=Rort

>>>> Because both Apple and Google choose to avoid
>>>> the taxes that the law requires them to pay.

>>> Nope not in the least.

>> Wrong.

> Even the Congress critters aren't saying they did anything illegal.

No one said what they did is illegal.

> The very carefully use the term avoidance since that has legal meaning
> that is very different from evasion (this one being the illegal part).

>>> It is tax evasion when they don't pay what the laws requires them to
>>> pay.

> You have any evidence of that, then bring it on.

They choose not to repatriate what they earn outside the US
because they would have to pay 35% tax on that if they did.

> Nobody has been raided by the IRS or
> Federal Marshalls for underpayment of taxes.

Because doing that is not illegal.

>> And that is precisely what they are doing when they deliberately
>> choose not to repatriate the money they earn out of the country to
>> the US where they would have to pay a 35% tax on that if they did.

> Not according to current tax laws.

Wrong.

>>> Even though some Senators are using avoidance in a
>>> way that implies otherwise, it well established in the
>>> US law that avoidance of taxes is perfectly legal.

>> Never said it wasn't legal. Its clearly avoiding the taxes
>> the law says they have to pay, most obviously with all
>> that foreign cash they choose to keep out of the US.

> If you aren't paying taxed the law says they **have** to pay,
> that is indeed illegal. Otherwise they wouldn't have to pay it.

But they don�t have to pay it if the money does not return to the US.

Which is why it doesn�t.

>>> I commend to you the words of Judge Learned Hand:
>>> "Anyone may arrange his affairs so that his taxes shall be as low as
>>> possible; he is not bound to choose that pattern which best pays the
>>> treasury. There is not even a patriotic duty to increase one's taxes.
>>> Over and over again the Courts have said that there is nothing sinister
>>> in so arranging affairs as to keep taxes as low as possible. Everyone
>>> does it, rich and poor alike and all do right, for nobody owes any
>>> public duty to pay more than the law demands."

>> Just the sort of mindless bullshit that only a judge could spew.

> You are kidding right?

No.

> You aren't really trying to tell me that people should pay
> more than they have to under the laws and there is no right
> to pay up to what you actually owe but not over, are you?

Having fun thrashing that straw man ?

>>> Unless, apparently it offends the sensitivities of some
>>> CongressCritters.

>> It offends the sensibilitys of US taxpayers too.

> YOUR sensibilities.

US taxpayer sensibilitys too.

> Obviously not mine and would doubt others on the list.

It isnt' a list. It�s a newsgroup.

> So, we should base tax policy on what offends you?

It doesn�t just offend me.

>> Get back to us when they move all the manufacturing
>> of iphones, ipads, ipods back to the US.

>> Taint gunna happen.

> Why should they move all iPhones, etc., back to the US. It isn't the
> only market. Heck, IIRC, China is the biggest smartphone market now.

Not for iphones it isnt.

Rod Speed

unread,
May 24, 2013, 7:20:50 PM5/24/13
to
Kurt Ullman <kurtu...@yahoo.com> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>> It's madness,

>> No, its what has avoided another great depression or worse.

> For now.

We aren't going to seen another great depression or worse.

The unemployment rate barely made it into double digits
for a couple of quarters and then headed back down again.

That�s nothing like what was seen in the great depression.

> We'll see what happens longer term when the Fed tries to unwind it.

We won't see another great depression or worse, you watch.

>> They arent loopholes. They are avoiding repatriating the money
>> they earn out of the country because if they did move it back
>> to the US, they would have to pay 35% tax on that.

> But they are doing legally.

No one said they weren't.

> Avoidance is illegal even if it does offend you.

It offends more than just me.

>>> people were bought by one company to pass a bad law, and now
>>> they think they can collect from every company that benefits from
>>> it. Apple's best defense here, at least in the eyes of the public,
>>> would be to call the lawmakers on the bullshit laws they made.

>> Nothing bullshit about the laws that require Apple to
>> pay 35% tax on the money they earn out of the country.

> But there is NO law that says that until they bring it on shore.
> None. Zilch. Nada. Bupkus. etc.

Wrong.

nospam

unread,
May 24, 2013, 7:25:49 PM5/24/13
to
In article <b0aant...@mid.individual.net>, Rod Speed
<rod.sp...@gmail.com> wrote:

> > Even the Congress critters aren't saying they did anything illegal.
>
> No one said what they did is illegal.

then there's no issue.

> >>> It is tax evasion when they don't pay what the laws requires them to
> >>> pay.
>
> > You have any evidence of that, then bring it on.
>
> They choose not to repatriate what they earn outside the US
> because they would have to pay 35% tax on that if they did.

it's not illegal.

if you don't like it, get the laws changed.

> > Why should they move all iPhones, etc., back to the US. It isn't the
> > only market. Heck, IIRC, China is the biggest smartphone market now.
>
> Not for iphones it isnt.

<http://www.nbcnews.com/technology/china-overtakes-us-largest-smartphone-
market-118874>
For the first time, China has surpassed the United States to become
the world's largest smartphone market by volume.

Kurt Ullman

unread,
May 24, 2013, 7:27:20 PM5/24/13
to
In article <b0ab0i...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:


> >> They arent loopholes. They are avoiding repatriating the money
> >> they earn out of the country because if they did move it back
> >> to the US, they would have to pay 35% tax on that.
>
> > But they are doing legally.
>
> No one said they weren't.
Actually have said quite a few times that what they were doing was
illegal.

> > But there is NO law that says that until they bring it on shore.
> > None. Zilch. Nada. Bupkus. etc.
>
> Wrong.

Find it for me, then. I can't find it in the tax code or anywhere
else.

D.F. Manno

unread,
May 24, 2013, 7:37:31 PM5/24/13
to
In article <519ece3e$0$64325$c3e8da3$5e5e...@news.astraweb.com>,
JF Mezei <jfmezei...@vaxination.ca> wrote:

> On 13-05-23 20:44, Alan Browne wrote:
> >
> > https://www.nytimes.com/2013/05/24/business/making-companies-pay-taxes-the-m
> > ccain-way.html?pagewanted=2&ref=business
>
> What is mising from the discussion here are the benefits to the american
> economy if money earned overseas is patriated to the USA instead of left
> in other countries.
>
> The issue spans more than just taxes the USA govt can collect. Consider
> the "quantitative easing" to help spur the economy if Apple were allowed
> to bring in tax free 100 billion bucks.

This country doesn't tax corporations enough as is and you want to let
them have tax-free billions? Fuck no!

What makes you think that companies won't take the repatriated profits
and just distribute them to their shareholders, making the rich richer
and sucking the money out of the economy?

--
D.F. Manno | dfm...@mail.com
GOP delenda est!
Message has been deleted

Rod Speed

unread,
May 24, 2013, 8:19:38 PM5/24/13
to
nospam <nos...@nospam.invalid> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>> What they ACTUALLY just did is avoid repatriating
>> the cash they have outside the country back to the US
>> where they would have to pay 35% tax on that money.

> completely legal.

Never said it wasn't.

I JUST said that they didn't actually borrow money to pay
the dividend, they did that to avoid paying tax on it.

Rod Speed

unread,
May 24, 2013, 8:22:49 PM5/24/13
to
nospam <nos...@nospam.invalid> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>>>> just as ordinary taxpayers do.

>>>> Nothing like ordinary taxpayers do in fact.

>>> they use different forms, but the concept is identical.

>> It's just not possible for ordinary taxpayers to get away
>> with claiming that they earned the bulk of their income
>> in the Bahamas when their work is in the US.

> depends how much time they spend
> there and how much they earn there.

Very few ORDINARY TAXPAYERS do the bulk of that in the Bahamas.

>>>>>>> instead of asking "what can we do to get you to bring
>>>>>>> that money into the USA and help our economy ?"

>>>>>> Because the answer to that is obvious. There is nothing
>>>>>> that the US can do that will ever get Apple to make its
>>>>>> products in the US again, because labor costs are so
>>>>>> much lower in places like China.

>>>>> except that apple makes a lot of stuff in the usa,

>>>> It has a hell of a lot more stuff manufactured for them outside the
>>>> USA.

>>> so what?

>> So apple has a hell of a lot more made for them out of the USA.

> so what?

So apple has a hell of a lot more made for them out of the USA.

>>> the fact is they are moving some production to the usa,

>> We'll see...

> and that will be in a little over 2 weeks.

We'll see...

>>> which you said would never happen. it's *happening*.

>> Get back to us when they move the manufacturing of
>> iphones, ipads, ipods, which they manufacture in VASTLY
>> greater volume than just one Mac line, back to the US.

> not the issue.

Bullshit.

Rod Speed

unread,
May 24, 2013, 8:25:35 PM5/24/13
to
Kurt Ullman <kurtu...@yahoo.com> wrote
> Rod Speed <rod.sp...@gmail.com> wrote
>> nospam <nos...@nospam.invalid> wrote
>>> Rod Speed <rod.sp...@gmail.com> wrote

>>>>> just as ordinary taxpayers do.

>>>> Nothing like ordinary taxpayers do in fact.

>>> they use different forms, but the concept is identical.

>> It's just not possible for ordinary taxpayers to get away
>> with claiming that they earned the bulk of their income
>> in the Bahamas when their work is in the US.

> Actually it is.

Actually, it isnt.

> If you meet certain requirements, the IRS allows you to
> exclude up to $80,000 of your income from being taxed.

Nothing like what Apple and Google are doing.

> You may also be able to deduct certain
> amounts you paid for your housing.

Nothing like what Apple and Google are doing.

> You can also deduct some expenses like non-
> business travel back to the US in some cases.

Nothing like what Apple and Google are doing.

>> Separate matter entirely to how they go about minimising
>> the tax they pay. What an operation like Apple or Google
>> does isnt even possible for an ordinary taxpayer to do.

> Probably because Corp taxes are different from personal taxes.

So it is, as I said, nothing like what ordinary taxpayers do.

Rod Speed

unread,
May 24, 2013, 8:27:52 PM5/24/13
to
nospam <nos...@nospam.invalid> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>> Even the Congress critters aren't saying they did anything illegal.

>> No one said what they did is illegal.

> then there's no issue.

Wrong, as always.

>>>>> It is tax evasion when they don't pay what the laws requires them to
>>>>> pay.

>>> You have any evidence of that, then bring it on.

>> They choose not to repatriate what they earn outside the US
>> because they would have to pay 35% tax on that if they did.

> it's not illegal.

No one ever said it was.

> if you don't like it, get the laws changed.

Not even possible for the laws to change to tax that.

>>> Why should they move all iPhones, etc., back to the US. It isn't the
>>> only market. Heck, IIRC, China is the biggest smartphone market now.

>> Not for iphones it isnt.

> <http://www.nbcnews.com/technology/china-overtakes-us-largest-smartphone-market-118874>

That aint iphones.

> For the first time, China has surpassed the United States to
> become the world's largest smartphone market by volume.

That aint iphones.

Rod Speed

unread,
May 24, 2013, 8:30:22 PM5/24/13
to
Kurt Ullman <kurtu...@yahoo.com> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>>> They arent loopholes. They are avoiding repatriating the money
>>>> they earn out of the country because if they did move it back
>>>> to the US, they would have to pay 35% tax on that.

>>> But they are doing legally.

>> No one said they weren't.

> Actually have said quite a few times that what they were doing was
> illegal.

Then you won't have any difficulty in citing a single
post of mine where I ever said anything of the sort.

>>> But there is NO law that says that until they bring it on shore.
>>> None. Zilch. Nada. Bupkus. etc.

>> Wrong.

> Find it for me, then. I can't find it in the tax code or anywhere else.

Your problem, as always.

Steve Hix

unread,
May 24, 2013, 8:33:16 PM5/24/13
to
In article <dfmanno-B3582C...@news.albasani.net>,
"D.F. Manno" <dfm...@mail.com> wrote:
>
> What makes you think that companies won't take the repatriated profits
> and just distribute them to their shareholders, making the rich richer
> and sucking the money out of the economy?

Those rich shareholders will just pile up bullion in their basements and cackle
maniacally as they count their ill-gotten gains, right? They're going to spend
the money, one way or another, to either make more money, or get stuff they want
to pile up in their basements, etc etc etc

For crying out loud, Scrooge McDuck cartoons were not actually documentaries.

Get a grip, man.

Rod Speed

unread,
May 24, 2013, 8:38:37 PM5/24/13
to
Lewis <g.k...@gmail.com.dontsendmecopies> wrote
> Rod Speed <rod.sp...@gmail.com> wrote
> No.

Yep.

> You are 100% wrong on that.

We'll see...

> US Tax law does not require they bring the money into the US

Never said it did.

> and does not tax money that is not brought into the US.

Never said it did.

> Apple is 100% within the law.

Never said it wasn�t.

nospam

unread,
May 24, 2013, 8:52:38 PM5/24/13
to
In article <b0aeu8...@mid.individual.net>, Rod Speed
<rod.sp...@gmail.com> wrote:

> >>>>> It is tax evasion when they don't pay what the laws requires them to
> >>>>> pay.
>
> >>> You have any evidence of that, then bring it on.
>
> >> They choose not to repatriate what they earn outside the US
> >> because they would have to pay 35% tax on that if they did.
>
> > it's not illegal.
>
> No one ever said it was.

if it's legal, then there's no issue.

> > if you don't like it, get the laws changed.
>
> Not even possible for the laws to change to tax that.

it's very possible and actually what apple is asking for, but it won't
be easy.

> >>> Why should they move all iPhones, etc., back to the US. It isn't the
> >>> only market. Heck, IIRC, China is the biggest smartphone market now.
>
> >> Not for iphones it isnt.
>
> > <http://www.nbcnews.com/technology/china-overtakes-us-largest-smartphone-mar
> > ket-118874>
>
> That aint iphones.
>
> > For the first time, China has surpassed the United States to
> > become the world's largest smartphone market by volume.
>
> That aint iphones.

iphones are smartphones.

Savageduck

unread,
May 24, 2013, 8:55:37 PM5/24/13
to
However, paying dividends to US stock holders from Apple's foreign held
funds, would be one way to repatriate some of those funds without tax
consequences to Apple.
The recipients of those paid dividends (individuals, retirement funds,
or investment funds) would have had tax consequences regardless of the
source of their dividend check.

--
Regards,

Savageduck

Savageduck

unread,
May 24, 2013, 8:57:17 PM5/24/13
to
Yup! I was thinking that myself.

--
Regards,

Savageduck

JF Mezei

unread,
May 24, 2013, 9:12:14 PM5/24/13
to
On 13-05-24 20:55, Savageduck wrote:

> However, paying dividends to US stock holders from Apple's foreign held
> funds, would be one way to repatriate some of those funds without tax
> consequences to Apple.


Is this possible ? Could Apple USA patriate 50 billion from Apple
Ireland and isseu 50 billion worth of dividends without having to
trigger that 35% tax ?



George Kerby

unread,
May 24, 2013, 9:21:02 PM5/24/13
to



On 5/24/13 6:37 PM, in article
dfmanno-B3582C...@news.albasani.net, "D.F. Manno"
Poor thing, bless your heart! Such anger-my goodness!

Rod Speed

unread,
May 24, 2013, 11:36:51 PM5/24/13
to
nospam <nos...@nospam.invalid> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>>>>>> It is tax evasion when they don't pay what the laws requires them to
>>>>>>> pay.

>>>>> You have any evidence of that, then bring it on.

>>>> They choose not to repatriate what they earn outside the US
>>>> because they would have to pay 35% tax on that if they did.

>>> it's not illegal.

>> No one ever said it was.

> if it's legal, then there's no issue.

Wrong when it isnt even possible to do the law so that operations
like Google and Apple pay the tax that corporates are required to pay.

Its legal export most jobs out of the country too.

Doesn't mean that there is no issue with doing that either.

>> > if you don't like it, get the laws changed.

>> Not even possible for the laws to change to tax that.

> it's very possible

Have fun pointing to a single country that has actually done that.

> and actually what apple is asking for,

Bullshit.

> but it won't be easy.

Its not even possible while ever operations like Google can claim that
their intellectual property is owned by their operation in some tax haven
and that they have to pay that operation in that tax haven for the use of
it.

>>>>> Why should they move all iPhones, etc., back to the US. It isn't the
>>>>> only market. Heck, IIRC, China is the biggest smartphone market now.

>>>> Not for iphones it isnt.

>>> <http://www.nbcnews.com/technology/china-overtakes-us-largest-smartphone-market-118874>

>> That aint iphones.

>>> For the first time, China has surpassed the United States to
>>> become the world's largest smartphone market by volume.

>> That aint iphones.

> iphones are smartphones.

iphones are a small subset of smartphones.

Rod Speed

unread,
May 24, 2013, 11:40:12 PM5/24/13
to
Savageduck <savageduck1@{REMOVESPAM}me.com> wrote
> nospam <nos...@nospam.invalid> wrote
>> Rod Speed <rod.sp...@gmail.com> wrote

>>> What they ACTUALLY just did is avoid repatriating
>>> the cash they have outside the country back to the US
>>> where they would have to pay 35% tax on that money.

>> completely legal.

> However, paying dividends to US stock holders from Apple's foreign held
> funds, would be one way to repatriate some of those funds without tax
> consequences to Apple.

That's just plain wrong. The reason that would have tax consequences
to Apple is why they decided its cheaper to issue bonds that pay a
cheaper discount rate than the 35% they would have to pay on those
foreign held funds to use them to pay dividends by their US operation.

> The recipients of those paid dividends (individuals, retirement
> funds, or investment funds) would have had tax consequences
> regardless of the source of their dividend check.

But Apple would have to pay 35% on those funds before they
were paid out to those as dividends.

Rod Speed

unread,
May 24, 2013, 11:42:29 PM5/24/13
to


"D.F. Manno" <dfm...@mail.com> wrote in message
news:dfmanno-B3582C...@news.albasani.net...
It isnt just the rich that get dividends on stocks.

> and sucking the money out of the economy?

That doesn�t happen either. That money still ends up in the economy.

Not as much of it does than if it ended up as taxes paid tho.

Rod Speed

unread,
May 24, 2013, 11:43:04 PM5/24/13
to


"Savageduck" <savageduck1@{REMOVESPAM}me.com> wrote in message
news:2013052417571753057-savageduck1@REMOVESPAMmecom...
Pity it mangles the real story.

Rod Speed

unread,
May 24, 2013, 11:46:00 PM5/24/13
to


JF Mezei <jfmezei...@vaxination.ca> wrote
> Savageduck wrote

>> However, paying dividends to US stock holders from Apple's
>> foreign held funds, would be one way to repatriate some of
>> those funds without tax consequences to Apple.

> Is this possible ?

Nope, that's why Apple chose to issue bonds that pay
a derisory rate of return to pay those dividends instead
of paying 35% on the repatriated foreign held funds.

AND what they pay on the bonds is ALSO a deductable for Apple too.

> Could Apple USA patriate 50 billion from Apple
> Ireland and isseu 50 billion worth of dividends
> without having to trigger that 35% tax ?

Nope, and that's why they chose not to go that route.

Savageduck

unread,
May 24, 2013, 11:51:57 PM5/24/13
to
Just a thought.

The stock holder, whether in the USA, Canada, UK, Ireland, etc., holds
Apple stock, not Apple USA or Apple Ireland, but Apple stock.

Apple announces a dividend distribution, and a draft from Apple's Irish
funds arrives at the US stock holder's mail box. The dividend is paid.
Apple USA doesn't handle the funds at all. The US stock holder has his
dividend and the tax liabilities that go along with them.

--
Regards,

Savageduck

Savageduck

unread,
May 24, 2013, 11:54:13 PM5/24/13
to
Why? Considering you are making your assumptions from somewhere South
of the equator and I am making mine from the USA.

--
Regards,

Savageduck

nospam

unread,
May 24, 2013, 11:58:00 PM5/24/13
to
In article <b0aq0l...@mid.individual.net>, Rod Speed
<rod.sp...@gmail.com> wrote:

> >> > if you don't like it, get the laws changed.
>
> >> Not even possible for the laws to change to tax that.
>
> > it's very possible
>
> Have fun pointing to a single country that has actually done that.
>
> > and actually what apple is asking for,
>
> Bullshit.

tim cook explicitly said it at the hearing.

> > but it won't be easy.
>
> Its not even possible while ever operations like Google can claim that
> their intellectual property is owned by their operation in some tax haven
> and that they have to pay that operation in that tax haven for the use of
> it.

google doesn't make laws, and they might even agree to the proposed
changes.

> >>>>> Why should they move all iPhones, etc., back to the US. It isn't the
> >>>>> only market. Heck, IIRC, China is the biggest smartphone market now.
>
> >>>> Not for iphones it isnt.
> >>>
> >>> <http://www.nbcnews.com/technology/china-overtakes-us-largest-smartphone-m
> >>> arket-118874>
>
> >> That aint iphones.
>
> >>> For the first time, China has surpassed the United States to
> >>> become the world's largest smartphone market by volume.
>
> >> That aint iphones.
>
> > iphones are smartphones.
>
> iphones are a small subset of smartphones.

actually a very big subset.

JF Mezei

unread,
May 25, 2013, 12:11:08 AM5/25/13
to
On 13-05-24 23:51, Savageduck wrote:

> The stock holder, whether in the USA, Canada, UK, Ireland, etc., holds
> Apple stock, not Apple USA or Apple Ireland, but Apple stock.

AAPL represents Apple USA, a coprporation headquartered at Cupertino and
paying taxes in the USA, abiding by SEC laws and trading on a US stock
exchange.

Apple USA is the corporation which is the owner of shares of all its
subsidiaries.



Message has been deleted
Message has been deleted
Message has been deleted
Message has been deleted
Message has been deleted
Message has been deleted
Message has been deleted

Rod Speed

unread,
May 25, 2013, 2:47:58 AM5/25/13
to
Savageduck <savageduck1@{REMOVESPAM}me.com> wrote
> JF Mezei <jfmezei...@vaxination.ca> wrote
>> Savageduck wrote

>>> However, paying dividends to US stock holders from Apple's foreign held
>>> funds, would be one way to repatriate some of those funds without tax
>>> consequences to Apple.

>> Is this possible ? Could Apple USA patriate 50 billion from Apple
>> Ireland and isseu 50 billion worth of dividends without having to
>> trigger that 35% tax ?

> Just a thought.

Too radical by far.

> The stock holder, whether in the USA, Canada, UK, Ireland, etc., holds
> Apple stock, not Apple USA or Apple Ireland, but Apple stock.

While that's true of Apple, it isnt true of all corporates or even all US
corporates.

It isnt true of Murdoch's News for example.

> Apple announces a dividend distribution, and a draft from Apple's Irish
> funds arrives at the US stock holder's mail box. The dividend is paid.
> Apple USA doesn't handle the funds at all.

That isnt legally possible, because the legal entity paying the
dividend US corporation.

> The US stock holder has his dividend and the tax liabilities that go along
> with them.

Don't you think that Apple would have done it that way if it was legally
possible ?


Rod Speed

unread,
May 25, 2013, 2:50:05 AM5/25/13
to
Savageduck <savageduck1@{REMOVESPAM}me.com> wrote
> Rod Speed <rod.sp...@gmail.com> wrote
>> Savageduck <savageduck1@{REMOVESPAM}me.com> wrote
>>> nospam <nos...@nospam.invalid> wrote
>>>> Rod Speed <rod.sp...@gmail.com> wrote

>>>>> What they ACTUALLY just did is avoid repatriating
>>>>> the cash they have outside the country back to the US
>>>>> where they would have to pay 35% tax on that money.

>>>> completely legal.

>>> However, paying dividends to US stock holders from Apple's
>>> foreign held funds, would be one way to repatriate some of
>>> those funds without tax consequences to Apple.

>> That's just plain wrong. The reason that would have tax consequences
>> to Apple is why they decided its cheaper to issue bonds that pay a
>> cheaper discount rate than the 35% they would have to pay on those
>> foreign held funds to use them to pay dividends by their US operation.
>>> The recipients of those paid dividends (individuals, retirement funds,
>>> or investment funds) would have had tax consequences regardless of the
>>> source of their dividend check.

>> But Apple would have to pay 35% on those funds
>> before they were paid out to those as dividends.

> Why?

Because that is US law.

> Considering you are making your assumptions

They arent assumptions, that's US law.

> from somewhere South of the equator
> and I am making mine from the USA.

Anyone anywhere can check US law.

Rod Speed

unread,
May 25, 2013, 2:53:08 AM5/25/13
to
nospam <nos...@nospam.invalid> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>>>> if you don't like it, get the laws changed.

>>>> Not even possible for the laws to change to tax that.

>>> it's very possible

>> Have fun pointing to a single country that has actually done that.

>>> and actually what apple is asking for,

>> Bullshit.

> tim cook explicitly said it at the hearing.

That was just him trying to bullshit his way out of his predicament.

>>> but it won't be easy.

>> Its not even possible while ever operations like Google can claim that
>> their intellectual property is owned by their operation in some tax haven
>> and that they have to pay that operation in that tax haven for the use of
>> it.

> google doesn't make laws,

It isnt even possible to do the laws to avoid that situation.

> and they might even agree to the proposed changes.

They don't get any say on any proposed changes.

>>>>>>> Why should they move all iPhones, etc., back to the US. It isn't the
>>>>>>> only market. Heck, IIRC, China is the biggest smartphone market now.

>>>>>> Not for iphones it isnt.

>>>>> <http://www.nbcnews.com/technology/china-overtakes-us-largest-smartphone-market-118874>

>>>> That aint iphones.

>>>>> For the first time, China has surpassed the United States to
>>>>> become the world's largest smartphone market by volume.

>>>> That aint iphones.

>>> iphones are smartphones.

>> iphones are a small subset of smartphones.

> actually a very big subset.

Bullshit.

Rod Speed

unread,
May 25, 2013, 2:56:10 AM5/25/13
to
Michelle Steiner <mich...@michelle.org> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>> I JUST said that they didn't actually borrow money to
>> pay the dividend, they did that to avoid paying tax on it.

> They accomplished both of those by borrowing the money.

They had plenty of cash to pay the dividend with.

The only reason they issued bonds to raise more
was because of the tax advantages of that approach.

> If it weren't to pay the dividend, they wouldn't have needed the money.

Irrelevant to why they borrowed the money to pay the dividend.

Rod Speed

unread,
May 25, 2013, 2:57:36 AM5/25/13
to
Michelle Steiner <mich...@michelle.org> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>> But instead of sending profits to Apple USA where they would be taxed
>>> AGAIN, they are sent to Apple Ireland where the cash can be parked tax
>>> free.

>> And that flouts US tax law.

> No, it doesn't.

Yes it does, because that money was not earned in Ireland.

> Look up the meaning of "flout".

No need, I know what it means.

Rod Speed

unread,
May 25, 2013, 2:59:21 AM5/25/13
to
Michelle Steiner <mich...@michelle.org> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>>> Apple is 100% within the law.

>> Never said it wasn�t.

> Yes you did;

No I didn't.

> look up the meaning of "flout".

No point, I know what it means.

> Heck, I'll look it up for you:

> From Apple's dictionary.app: "openly
> disregard (a rule, law or convention)"

Which says nothing useful about that comment at the top.

Kurt Ullman

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May 25, 2013, 7:33:58 AM5/25/13
to
In article <dfmanno-B3582C...@news.albasani.net>,
"D.F. Manno" <dfm...@mail.com> wrote:

> This country doesn't tax corporations enough as is and you want to let
> them have tax-free billions? Fuck no!

Exactly how much is "enough" and how did you decide on that point? (And
because it offends me personally is not a valid reason).
--
America is at that awkward stage. It's too late
to work within the system, but too early to shoot
the bastards."-- Claire Wolfe

Kurt Ullman

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May 25, 2013, 7:36:42 AM5/25/13
to
In article <b0aekp...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:

>
>
> Very few ORDINARY TAXPAYERS do the bulk of that in the Bahamas.
This is, of course availble to ANYONE working outside the US.
Including a few nurses I know,�quite a few oil rig workers, many
middle-level management people in corporations. In other words ordinary
taxpayers.

Kurt Ullman

unread,
May 25, 2013, 7:39:08 AM5/25/13
to
In article <b0aeq0...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:

> >>>> Nothing like ordinary taxpayers do in fact.
>
> >>> they use different forms, but the concept is identical.
>
> >> It's just not possible for ordinary taxpayers to get away
> >> with claiming that they earned the bulk of their income
> >> in the Bahamas when their work is in the US.
>
> > Actually it is.
>
> Actually, it isnt.
Actually it is.


> Nothing like what Apple and Google are doing.
Nothing having to do with your original insertion. BTW: Did you
put this on a macro or did you hand type this every time?

>
> >> Separate matter entirely to how they go about minimising
> >> the tax they pay. What an operation like Apple or Google
> >> does isnt even possible for an ordinary taxpayer to do.
>
> > Probably because Corp taxes are different from personal taxes.
>
> So it is, as I said, nothing like what ordinary taxpayers do.
Well that is sorta inherent in the different part.

Kurt Ullman

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May 25, 2013, 7:40:53 AM5/25/13
to
In article <51a00fee$0$55092$c3e8da3$e408...@news.astraweb.com>,
JF Mezei <jfmezei...@vaxination.ca> wrote:

> On 13-05-24 20:55, Savageduck wrote:
>
> > However, paying dividends to US stock holders from Apple's foreign held
> > funds, would be one way to repatriate some of those funds without tax
> > consequences to Apple.
>
>
> Is this possible ? Could Apple USA patriate 50 billion from Apple
> Ireland and isseu 50 billion worth of dividends without having to
> trigger that 35% tax ?

Not as currently written. I also doubt they could anyway since dividends
come from AFTER tax profits.

Kurt Ullman

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May 25, 2013, 7:43:51 AM5/25/13
to
In article <2013052420515710679-savageduck1@REMOVESPAMmecom>,
Savageduck <savageduck1@{REMOVESPAM}me.com> wrote:

> Apple announces a dividend distribution, and a draft from Apple's Irish
> funds arrives at the US stock holder's mail box. The dividend is paid.
> Apple USA doesn't handle the funds at all. The US stock holder has his
> dividend and the tax liabilities that go along with them.

About the only way they could that currently, as far as I know, would be
to put the Irish company on the Stock Exchanges, sell the stock and then
pay the dividends. I suppose they MIGHT be able to spin it off.

Kurt Ullman

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May 25, 2013, 7:45:48 AM5/25/13
to
In article <michelle-056A6A...@news.eternal-september.org>,
Michelle Steiner <mich...@michelle.org> wrote:

> In article <2013052420541337335-savageduck1@REMOVESPAMmecom>,
> Savageduck <savageduck1@{REMOVESPAM}me.com> wrote:
>
> > > But Apple would have to pay 35% on those funds before they were paid
> > > out to those as dividends.
> >
> > Why? Considering you are making your assumptions from somewhere South of
> > the equator and I am making mine from the USA.
>
> The money would have to be transferred from the coffers of the overseas
> corporation to those of Apple, Inc. before it could be paid as dividends;
> as soon as that happened, Apple would be on the hook for the 35% tax.

They could do it as a spin off Irish company. But why bother?

D.F. Manno

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May 25, 2013, 10:33:30 AM5/25/13
to
In article <sehix-0B7714....@5ad64b5e.bb.sky.com>,
Steve Hix <se...@NOSPAMmac.comINVALID> wrote:

> In article <dfmanno-B3582C...@news.albasani.net>,
> "D.F. Manno" <dfm...@mail.com> wrote:
> >
> > What makes you think that companies won't take the repatriated profits
> > and just distribute them to their shareholders, making the rich richer
> > and sucking the money out of the economy?
>
> Those rich shareholders will just pile up bullion in their
> basements and cackle maniacally as they count their ill-gotten
> gains, right? They're going to spend the money, one way or
> another, to either make more money, or get stuff they want to
> pile up in their basements, etc etc etc

Do you really think that the rich spend all of their income? How do you
think they get richer every year?

And no, money "invested" in the stock market does not contribute to the
economy. If I buy AAPL on the open market, the money does not go to
Apple to finance its operations. It's just a transfer payment from one
party to another.

> For crying out loud, Scrooge McDuck cartoons were not actually documentaries.
>
> Get a grip, man.

--
D.F. Manno | dfm...@mail.com
GOP delenda est!

George Kerby

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May 25, 2013, 11:18:24 AM5/25/13
to



On 5/25/13 9:33 AM, in article
dfmanno-36417D...@news.albasani.net, "D.F. Manno"
^^
Like he said.

Go find a building on Wall Street to OccuPoop on, and get over that Democrat
Demonizing of anyone that might have enough sense to try and save for
retirement and the future. EGADS, you are a TOOL!

George Kerby

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May 25, 2013, 11:23:35 AM5/25/13
to



On 5/25/13 9:33 AM, in article
dfmanno-36417D...@news.albasani.net, "D.F. Manno"
<dfm...@mail.com> wrote:

> In article <sehix-0B7714....@5ad64b5e.bb.sky.com>,
> Steve Hix <se...@NOSPAMmac.comINVALID> wrote:
>
>> In article <dfmanno-B3582C...@news.albasani.net>,
>> "D.F. Manno" <dfm...@mail.com> wrote:
>>>
>>> What makes you think that companies won't take the repatriated profits
>>> and just distribute them to their shareholders, making the rich richer
>>> and sucking the money out of the economy?
>>
>> Those rich shareholders will just pile up bullion in their
>> basements and cackle maniacally as they count their ill-gotten
>> gains, right? They're going to spend the money, one way or
>> another, to either make more money, or get stuff they want to
>> pile up in their basements, etc etc etc
>
> Do you really think that the rich spend all of their income? How do you
> think they get richer every year?

Actually many lose money and many gain.
>
> And no, money "invested" in the stock market does not contribute to the
> economy. If I buy AAPL on the open market, the money does not go to
> Apple to finance its operations. It's just a transfer payment from one
> party to another.
>

I see you have never taken any course in Economics and studied open market
theory when you were wasting your parents' $$$ in college.
>> For crying out loud, Scrooge McDuck cartoons were not actually documentaries.
>>
>> Get a grip, man.

--
Thought for the day -- "Isn't it strange that after a bombing, everyone
blames the bomber...but after a shooting, the problem is the gun!"


nospam

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May 25, 2013, 12:31:40 PM5/25/13
to
In article <michelle-A5CAA7...@news.eternal-september.org>,
Michelle Steiner <mich...@michelle.org> wrote:

> > I JUST said that they didn't actually borrow money to pay the dividend,
> > they did that to avoid paying tax on it.
>
> They accomplished both of those by borrowing the money. If it weren't to
> pay the dividend, they wouldn't have needed the money.

if it weren't for the screwed up tax code, they wouldn't have needed to
borrow the money.

nospam

unread,
May 25, 2013, 12:31:42 PM5/25/13
to
In article <michelle-DB37D8...@news.eternal-september.org>,
Michelle Steiner <mich...@michelle.org> wrote:

> > > iphones are a small subset of smartphones.
> >
> > actually a very big subset.
>
> But not in China.

yes in china.

note that very big is not the same as biggest.

<http://www.forbes.com/sites/chuckjones/2013/04/17/iphone-gaining-share-
in-urban-china-ebbing-and-flowing-in-europe-and-losing-share-in-japan/>
Apple�s iPhone market share in Urban China has been on a steady climb
the past six months crossing over 25% for the first time in February
while Android/Google has also increased its share from 65.2% to
68.7%.� The big losers were Symbian moving from 7.7% to 3.1% share
and Windows/Microsoft�s share declining from 5.7% to 1.4%

25% is a big chunk, just behind samsung, who has 28%.

windows phone has a small subset, as does symbian.

china is a huge growth area and apple is putting a lot of effort into
that market.

Doc O'Leary

unread,
May 25, 2013, 1:27:53 PM5/25/13
to
In article <b0a93h...@mid.individual.net>,
"Rod Speed" <rod.sp...@gmail.com> wrote:

> Doc O'Leary <drolear...@2q2013.subsume.com> wrote
>
> > Real value is no longer needed to make loans. Banks just print
> > up money out of thin air when they want to borrow it out.
>
> Even US banks don�t get to do that.

Of course they do; money gets printed when someone says it does, not
when it is needed to represent real value. The whole economy is based
on fiat money. Worse, it is mired in debt and running at a deficit.
We're in a hole and yet we keep digging *faster*.

> > That's why you can't find a savings account that pays a decent rate of
> > interest,
>
> No, that is because the Fed has driven interest rates
> to the lowest they have been for a very long time.

Yes, because it's all about concentrating wealth rather than building a
stable economy these days. Just like low prices for foreign goods
*seem* to be good but are harmful to the local economy in the long run,
low interest rates *given by the people who print money from nothing* is
a recipe for disaster in the future. Like most people, you fail to see
that and are thus part of the problem.

> > and sometimes even the interest rate on the
> > the loans *themselves* is less than inflation.
>
> Because the Fed has driven interest rates to
> the lowest they have been for a very long time.

If you don't think that's madness, you may be insane.

> > It's madness,
>
> No, its what has avoided another great depression or worse.

Hardly. Genuine fixes to the system are what will keep things from
getting worse. All that's happing now is a numbers game that is only
delaying the inevitable. Extracting a few billion from Apple changes
nothing; the government would blow through that money in mere days.

> > but people bury their heads in the sand the same
> > way they do when they can buy things made in
> > [insert foreign economy here] to save a few cents
>
> They save a hell of a lot more than just a few cents.

No, they don't. Instead the *lose* large sums of money from the local
economy. Who pays your salary? If you spend $5 of it for something
made next door, that money is likely to circulate back to you faster and
retain more of its value. The *actual* cost of your $5 purchase might
only be $1. But if the majority of that product's value comes from
overseas, you might pay only $4 at the register, but *nothing* comes
back to you. You'll go bankrupt if you keep exporting value like that.
So who pays your salary? If it isn't China (or wherever), you're a fool
to think you're coming out ahead when you ship value overseas.

Getting back to Apple. It's a more complex picture for them because
they actually do do business worldwide. The fact that they're looking
to move (some) Mac manufacturing back into the US means they're slightly
more on top of the ball that most corporations. But, still, there is an
imbalance in value that needs to be addressed if you want to have a
sustainable economy in this country. The problem is that no
corporation, even Apple, will simply give away the value it has
extracted from the broken system.

> And I bet that what you are using to post on
> wasn�t made in the US unless its an antique.

Indeed, but at least I'm not fooling myself into thinking it's OK.

> > As far as this Apple kerfuffle is concerned, my understanding
> > is that the main reason they're a target is that they're using
> > (some of) the same loopholes that other corporations abuse,
>
> They arent loopholes. They are avoiding repatriating the money
> they earn out of the country because if they did move it back
> to the US, they would have to pay 35% tax on that.

Again, it's complex for a global operation like Apple. They're not (as
far as I know) *directly* offshoring value into the Caymen Islands or
the like, but it doesn't change the fact that they *have* moved value
out of the country to the overall detriment to the economy over the past
few decades. There is a price to pay for that, and right now we are
*all* paying it while the corporations get richer. Apple needs to make
up for the harm it has done, as should all corporations. But it will
all just be drops in the bucket until the government gets its own act
together.

> > but they're doing it without having lined the pockets of the politicians.
>
> Even sillier.
>
> > Apple doesn't lobby as much as some corrupt individuals would like;
>
> They don�t need to lobby, they are raking it in without doing that.

You support my point. There is no reason to single out Apple at this
time, other than the fact that their massive offshoring of value didn't
fatten the wallet of corrupt politicians. Rather than simply changing
the laws so that they benefit We The People, they want Apple to buy
special favors.

> > people were bought by one company to pass a bad law, and now
> > they think they can collect from every company that benefits from
> > it. Apple's best defense here, at least in the eyes of the public,
> > would be to call the lawmakers on the bullshit laws they made.
>
> Nothing bullshit about the laws that require Apple to
> pay 35% tax on the money they earn out of the country.

It's 100% bullshit when it was earned by taking jobs out of the country.
That's bad for us and it's bad for Apple (as a US-based corporation,
anyway; wouldn't it be cute if *that* changed?). Look, you're just
being too simplistic about the problem. A simple tax doesn't in and of
itself fix things, because the government itself remains broken. The
economics of the situation demand to know what *becomes* of the money
that they bring back in, and that would require lawmakers to actually do
their job.

> > There are still problems with wealth accumulation, by Apple and
> > others, when it comes to keeping a functioning world economy.
> > It's all a big mess of people denying reality as they exploit resources.
> > Even if they took all of Apple's profits as "taxes", it wouldn't make
> > a sustainable system. Until some actual science is introduced into
> > the process, it remains fundamentally broken in the long term.
>
> Not even possible to apply science to tax law.

Then we're all doomed. I think you're wrong, though, not that that will
change anything. It is up to you to elect scientists instead of career
politicians.

> > Of course, given some of the battles I've had with the App Store
> > review process, science isn't exactly overabundant at Apple, either.
>
> Or in politics in spades.

You get what you vote for. So long as people like you are directly
hostile to reality, we will all pay the price.

--
iPhone apps that matter: http://appstore.subsume.com/
My personal UDP list: 127.0.0.1, localhost, googlegroups.com, theremailer.net,
and probably your server, too.

Paul Magnussen

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May 25, 2013, 2:04:00 PM5/25/13
to
Rod Speed wrote:

> They flout the law by deliberately moving the the profits they make to
> places where they are not taxed on that profit.

Last I heard, no one is obliged to arrange their affairs so that the
taxman can take the maximum bite of their income.

Paul Magnussen
Message has been deleted

Rod Speed

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May 25, 2013, 3:32:37 PM5/25/13
to
Kurt Ullman <kurtu...@yahoo.com> wrote
> Rod Speed <rod.sp...@gmail.com> wrote

>> Very few ORDINARY TAXPAYERS do the bulk of that in the Bahamas.

> This is, of course availble to ANYONE working outside the US.

No it is not. They still have to pay US income tax on their income.

News doesn�t with what they claim they earn in the Bahamas.

> Including a few nurses I know, quite a few oil rig workers,
> many middle-level management people in corporations.
> In other words ordinary taxpayers.

A small subset of total US ordinary taxpayers.

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