OT: Cramer sees AAPL @ 1500 in three years or less

[George Kerby]

<http://www.thestreet.com/story/11921204/1/apple-bottom-i-told-you-so.html?p
uc=yahoo&cm_ven=YAHOO>

[Fred Moore]

In article <CDB66BCB.9B8AD%ghost_...@hotmail.com>,
George Kerby <ghost_...@hotmail.com> wrote:

> <http://www.thestreet.com/story/11921204/1/apple-bottom-i-told-you-so.html?p
> uc=yahoo&cm_ven=YAHOO>

I presume, Mr. Kerby, you do know who Jim Cramer is. For those who
don't, he's one of the loudmouth CRAPitalist shills who work for CNBC.
He, in particular, was one of those valiantly extolling the virtues of
AIG et al. back in 2009 -- right before they crashed.

Here is an excellent interview by Jon Stewart, who is always the most
polite with someone he detests, back in 2009:
<http://www.huffingtonpost.com/2009/03/12/jim-cramer-on-daily-show-_n_174
503.html>

While I do indeed hope Apple hits 1500, I certainly wouldn't take
Cramer's prognostications as any reliable indication it will happen.

--
The problem with Crapitalism is there is an infinite supply
of vicious, greedy bastards demanding everything for themselves
and happy to let everyone else pay the price.

[JF Mezei]

On 13-05-13 16:07, Fred Moore wrote:

> While I do indeed hope Apple hits 1500, I certainly wouldn't take
> Cramer's prognostications as any reliable indication it will happen.

What his article means is thet HE has stopped shorting AAPL, and thus no
longer wants to issue bad news about AAPL to make his shorts pay off.

Once a balloon has finished deflating, there is no more air to be pushed
out and you have to let it re-inflate it again.

Once other Wall Street Casino Analysts stop shorting AAPL and buy into
it, they too will stop issuing "such and such supplier has ordered less
plastic, so this must mean doom for Apple" stories.

It isn't one article that changes things but rather a trend. And his is
not the first one to start to poo-poo the AAPL naysayers.

[George Kerby]

On 5/13/13 3:07 PM, in article
fmoore-C4C1DA....@mx05.eternal-september.org, "Fred Moore"

<fmo...@gcfn.org> wrote:

> In article <CDB66BCB.9B8AD%ghost_...@hotmail.com>,
> George Kerby <ghost_...@hotmail.com> wrote:
>
>> <http://www.thestreet.com/story/11921204/1/apple-bottom-i-told-you-so.html?p
>> uc=yahoo&cm_ven=YAHOO>
>
> I presume, Mr. Kerby, you do know who Jim Cramer is. For those who
> don't, he's one of the loudmouth CRAPitalist shills who work for CNBC.
> He, in particular, was one of those valiantly extolling the virtues of
> AIG et al. back in 2009 -- right before they crashed.
>

Indeed I do know him to be a braggart - I just pass on what I see.

Thank you Mister Moore for your concern with my education...

[Fred Moore]

In article <5191856f$0$46989$c3e8da3$9b4f...@news.astraweb.com>,

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

> On 13-05-13 16:07, Fred Moore wrote:
>
> > While I do indeed hope Apple hits 1500, I certainly wouldn't take
> > Cramer's prognostications as any reliable indication it will happen.
>
> What his article means is thet HE has stopped shorting AAPL, and thus no
> longer wants to issue bad news about AAPL to make his shorts pay off.

Excellent point, JF. Just the way the 'free market' works. However,
sooner or later it becomes clear that the emperor is indeed naked and
the amateur speculators (i.e. the fools who act on Cramer et al.'s
advice) are parted with their money.

> Once a balloon has finished deflating, there is no more air to be pushed
> out and you have to let it re-inflate it again.
>
> Once other Wall Street Casino Analysts stop shorting AAPL and buy into
> it, they too will stop issuing "such and such supplier has ordered less
> plastic, so this must mean doom for Apple" stories.
>
> It isn't one article that changes things but rather a trend. And his is
> not the first one to start to poo-poo the AAPL naysayers.

Apple has always been a speculative stock, appropriate only for the
'let's take a gamble' portion of one's portfolio allocation.

--
Remember that Capitalism with out deniability is the same as poverty.
--Dilberr 2012.10.18

[JF Mezei]

On 13-05-14 11:03, Fred Moore wrote:

> Apple has always been a speculative stock, appropriate only for the
> 'let's take a gamble' portion of one's portfolio allocation.

This was the case in the past when AAPL didn't have dividends.

AAPL is being transformed into a stable blue chip stock. The balloon
was fully deflated by the Wall Street Casino Analysts's doom
preductions, and now that most of the speculation has been taken out of
the equation, the investor mix will also change into more long term blue
chip mentality instead of speculators wanting a quick buck.

Note that Cramer's prediction of $1500 shares is totally out of whack.


My fear is that the next target will be Google. It is now in the same
posistion as Apple was in its heydays of last year.

[George Kerby]

The greedy bastards make crack whores look like Mother Teresa...

<http://www.forbes.com/sites/johntamny/2013/05/22/apple-ceo-tim-cook-pounds-
another-nail-into-the-keynesian-coffin/?partner=yahootix>

[Bert]

In news:michelle-1EEF40...@news.eternal-september.org
Michelle Steiner <mich...@michelle.org> wrote:

> The one thing that the article manages to sidestep is that that money,
> for the most part, is just sitting there (probably accumulating
> interest), and is not being spent or in any otherwise being used
> productively.

Not being "used productively?"

So The State would be fully justified in confiscating any or all of it
to use as it sees fit?

Or perhaps you should get a cut, because you're just so darned
deserving?

--
be...@iphouse.com St. Paul, MN

[News]

On 5/22/2013 5:01 PM, Bert wrote:
> In news:michelle-1EEF40...@news.eternal-september.org
> Michelle Steiner <mich...@michelle.org> wrote:
>
>> The one thing that the article manages to sidestep is that that money,
>> for the most part, is just sitting there (probably accumulating
>> interest), and is not being spent or in any otherwise being used
>> productively.
>
> Not being "used productively?"

Right, not being reinvested in R&D and facilities, not being used to
hire, and accumulating a whole bupkus in interest. The usual reason
given being "uncertainty" and "the firm lacks visibility", as if life,
economies and outcomes were so predictable up until recently. Or maybe
it's just cowardly, risk/decision averse and obstructionist "managers".
Not exactly the "Do something. Lead or follow, but get out of the
way." of a Ted Turner.

[Warren Oates]

In article <XnsA1C8D68822D...@78.46.70.116>,

Bert <be...@iphouse.com> wrote:

> Or perhaps you should get a cut, because you're just so darned
> deserving?

Me first.
--
Where's the Vangelis music?
Pris' tongue is sticking out in in the wide shot after Batty has kissed her.
They have put back more tits into the Zhora dressing room scene.
-- notes for Blade Runner

[News]

On 5/22/2013 5:31 PM, Warren Oates wrote:
> In article <XnsA1C8D68822D...@78.46.70.116>,
> Bert <be...@iphouse.com> wrote:
>
>> Or perhaps you should get a cut, because you're just so darned
>> deserving?
>
> Me first.

You'll be treated fairly.

[DevilsPGD]

In the last episode of <XnsA1C8D68822D...@78.46.70.116>, Bert

<be...@iphouse.com> said:

>In news:michelle-1EEF40...@news.eternal-september.org
>Michelle Steiner <mich...@michelle.org> wrote:
>
>> The one thing that the article manages to sidestep is that that money,
>> for the most part, is just sitting there (probably accumulating
>> interest), and is not being spent or in any otherwise being used
>> productively.
>
>Not being "used productively?"
>
>So The State would be fully justified in confiscating any or all of it
>to use as it sees fit?

No. However, money that is effectively removed from "the system" can be
a significant cause of inflation, especially when consolidated in the
hands of a relative few who don't spend proportionally.

That isn't to say that taking it across the board is a good idea, but
neither is economic policies that encourage large amounts of money to
sit, relatively stagnant.

--
The nice thing about standards, there is enough for everyone to have their own.

[Kurt Ullman]

In article <michelle-D863D4...@news.eternal-september.org>,
Michelle Steiner <mich...@michelle.org> wrote:

>
> The problem is not that Apple is hoarding money overseas喫t's not that
> Apple is hoarding money逆he problem is that the tax laws are so messed up.
> Apple is not at fault for taking advantage of those tax laws as they exist.

SOmeone noted the dichotomy (although I might upgrade it to hypocrisy)
of individuals being exhorted to find every deduction that you are
legally entitled to, but for some reason Corps aren't supposed to do the
same thing.
--
America is at that awkward stage. It's too late
to work within the system, but too early to shoot
the bastards."-- Claire Wolfe

[News]

On 5/22/2013 8:21 PM, Kurt Ullman wrote:
> In article <michelle-D863D4...@news.eternal-september.org>,
> Michelle Steiner <mich...@michelle.org> wrote:
>
>>

>> The problem is not that Apple is hoarding money overseas�it's not that
>> Apple is hoarding money�the problem is that the tax laws are so messed up.

>> Apple is not at fault for taking advantage of those tax laws as they exist.
>
> SOmeone noted the dichotomy (although I might upgrade it to hypocrisy)
> of individuals being exhorted to find every deduction that you are
> legally entitled to, but for some reason Corps aren't supposed to do the
> same thing.
>

How is that relevant since Cook claimed in testimony that none of the
machinations actually save Apple a dime?

[Alan Browne]

On 2013.05.22 17:01 , Bert wrote:
> In news:michelle-1EEF40...@news.eternal-september.org
> Michelle Steiner <mich...@michelle.org> wrote:
>
>> The one thing that the article manages to sidestep is that that money,
>> for the most part, is just sitting there (probably accumulating
>> interest), and is not being spent or in any otherwise being used
>> productively.
>
> Not being "used productively?"
>
> So The State would be fully justified in confiscating any or all of it
> to use as it sees fit?

Where did you get that inane idea?

Money sitting in an account not invested is "sleeping". If inflation is
3% and interest is 2%, it's devaluating. Apple may be investing it more
aggressively in some cases but to look at their annual reports they are
mostly very conservative.

The US tax situation is so screwed up that Apple are actually
_borrowing_ money to pay dividends to shareholders rather than bringing
in cash from their accounts to pay the shareholders. It is cheaper to
pay that back (at a few %) out of future cash flows from US sales alone
than to re-patriate that cash with the current tax structure.

In the end:
.Apple lose out on investment opportunities in the US
.Shareholders lose out in future cash flows (interest paid in the
future - though that's abated by the tax code - ironic)
.The US loses out on tax income (Apple would re-patriate the cash if
it made sense - eg: a lower rate for offshore earnings.
.And Apple's overseas cash pile continues to pile up.

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

[Alan Browne]

On 2013.05.22 20:38 , Michelle Steiner wrote:

> And both Democrats and Republicans (with a few exceptions like Rand Paul)
> are furious with Apple because Apple is taking advantage of this situation.
> Curiously, they're not showing infuriation at other companies (e.g.,
> Microsoft and Google) for doing the same or similar things‹probably because
> those other companies don't have nearly as much money involved as does
> Apple.

Google and MS have big lobbying efforts in DC.

Apple's lobbying effort is relatively small - esp. when you consider
their size.

QUOTE The company spent about $2 million on lobbying last year, up from
$180,000 in 1999, records show. This year it is on pace to nearly
double last year's figure.

Apple's lobbying expenditures still pale in comparison with those
of Microsoft Corp., which spent $8.1 million in 2012, and Google,
which spent $16.5 million, records show.
ENDQUOTE Source
http://www.reuters.com/article/2013/05/22/us-usa-tax-apple-lobbying-idUSBRE94L1B320130522


Here's a nice one on GE (claims their tax department is considered a
"profit center" something usually not associates with the bean counters
and lawyers).

https://www.propublica.org/article/5-ways-ge-plays-the-tax-game

[JF Mezei]

AAPL should not be tied to Apple USA.

It should be an index fund tht contains ADRs from all of Apple's
subsidiaries around the world.

Each would issue their dividends and AAPL would basically combine them
into a single investment vehicle.

This way, profits made by Apple in France could make their way to AAPL
investors without having to be repatriated to the USA (with a second tax
on profits.

Or Apple Corp could move its headquarters to the bahamas or switzerland
or some low tax country where it would be easy to patriate profits from
around the world to distribute dividends.

I am really not compfrtable with Apple borrowing in the USA to make
dividend payments because this is cheaper than patriating funds from
overseas.

[JF Mezei]

On 13-05-22 21:56, Michelle Steiner wrote:

> It obviously saves Apple lots of money because if Apple brought that money
> into the USA, Apple would have to pay 35% income tax on it.

Not that simple. When Apple <country> keeps the money, it is likely they
have to pay local taxes on those profits.

Depending on the country, if they repatriate the money, they don't have
to pay local taxes because they end up paying taxes in USA.

But in other places, they would end up paying txes twice on it, once in
the origial country and once when patriated to the USA.

[News]

On 5/22/2013 9:56 PM, Michelle Steiner wrote:
> In article <knjnve$knt$1...@dont-email.me>, News <Ne...@Group.Post> wrote:
>
>>>> The problem is not that Apple is hoarding money overseas�it's not
>>>> that Apple is hoarding money�the problem is that the tax laws are so

>>>> messed up. Apple is not at fault for taking advantage of those tax
>>>> laws as they exist.
>>>
>>> SOmeone noted the dichotomy (although I might upgrade it to hypocrisy)
>>> of individuals being exhorted to find every deduction that you are
>>> legally entitled to, but for some reason Corps aren't supposed to do
>>> the same thing.
>>>
>>
>> How is that relevant since Cook claimed in testimony that none of the
>> machinations actually save Apple a dime?
>

> Got a reference for that? I couldn't find that statement anywhere.

>
> It obviously saves Apple lots of money because if Apple brought that money
> into the USA, Apple would have to pay 35% income tax on it.
>

"Apple said in a comment posted online on Monday it did not use "tax
gimmicks". It said the existence of its subsidiary Apple Operations
International in Ireland did not reduce Apple's U.S. tax liability, and
the company would pay more than $7 billion in U.S. taxes in fiscal 2013."

http://www.reuters.com/article/2013/05/21/us-usa-tax-apple-ireland-idUSBRE94K0IS20130521

[JF Mezei]

On 13-05-22 22:46, Michelle Steiner wrote:

> Yes, that simple, because of the loopholes, Apple doesn't pay much, if any,
> taxes to Ireland, which is where that money is.

But what happens to profits made in France, China , Germany etc ?
Doesn't Apple have to pay taxes there ?

Is the only advante of moving talready taxed profits from other
countries to Ireland that interest earned on the cash taxed at lower
rate then elsewhere ?

[News]

On 5/22/2013 10:45 PM, Michelle Steiner wrote:

> In article <knjtff$bco$1...@dont-email.me>, News <Ne...@Group.Post> wrote:
>
>>>> How is that relevant since Cook claimed in testimony that none of the
>>>> machinations actually save Apple a dime?
>>>
>>> Got a reference for that? I couldn't find that statement anywhere.
>>>
>>> It obviously saves Apple lots of money because if Apple brought that
>>> money into the USA, Apple would have to pay 35% income tax on it.
>>>
>>
>> "Apple said in a comment posted online on Monday it did not use "tax
>> gimmicks". It said the existence of its subsidiary Apple Operations
>> International in Ireland did not reduce Apple's U.S. tax liability, and
>> the company would pay more than $7 billion in U.S. taxes in fiscal
>> 2013."
>>
>> http://www.reuters.com/article/2013/05/21/us-usa-tax-apple-ireland-idUSBR
>> E94K0 IS20130521
>

> That in no way whatsoever means that he said that none of the machinations
> actually save Apple any money. What it does say is that he said that Apple
> pays all the taxes it is legally responsible for paying.
>

"Apple said ...the existence of its subsidiary Apple Operations
International in Ireland did not reduce Apple's U.S. tax liability..."

[Kurt Ullman]

In article <michelle-6108E8...@news.eternal-september.org>,
Michelle Steiner <mich...@michelle.org> wrote:

>
> The problem isn't in finding deductions; it's in finding loopholes. The
> situation is that the US doesn't tax Apple's money in Ireland because the
> money belongs to an corporation incorporated outside the US, and Ireland
> doesn't tax it because the money is controlled from outside Ireland.
>

Relatively few countries (last time I looked and it has been
awhile so that may have changed) tax even domestic corps for money made
outside their territories. Although there is a certain consistency in
that the US is one of only about 5 countries to tax their citizens on
income no matter where it is made.
(You can probably remember the second great British invasion when
Clapton, Elton John, a couple of Beatles and others came over to the US
to live to lessen their British taxes.)

[Kurt Ullman]

In article <519d79f3$0$55126$c3e8da3$e408...@news.astraweb.com>,

Actually it is the other way around. They still have to pay local taxes
pretty much no matter what happens with the money. In the US, they get a
credit for foreign taxes paid (just like I do with a couple of Canadian
stocks I own).

Also, FYI (and no dig intended) it is repatriated when you bring
something back inside the country.

If anyone is interested in a little background:
http://www.taxpolicycenter.org/taxtopics/encyclopedia/Foreign-Tax-Credit.
cfm

[George Kerby]

On 5/22/13 7:38 PM, in article
michelle-6108E8...@news.eternal-september.org, "Michelle
Steiner" <mich...@michelle.org> wrote:

> In article <PJudnZvdlvmE_ADM...@earthlink.com>,

> Kurt Ullman <kurtu...@yahoo.com> wrote:
>
>>> The problem is not that Apple is hoarding money overseas喫t's not that
>>> Apple is hoarding money逆he problem is that the tax laws are so messed
>>> up. Apple is not at fault for taking advantage of those tax laws as
>>> they exist.
>>
>> SOmeone noted the dichotomy (although I might upgrade it to hypocrisy)
>> of individuals being exhorted to find every deduction that you are
>> legally entitled to, but for some reason Corps aren't supposed to do the
>> same thing.
>

> The problem isn't in finding deductions; it's in finding loopholes. The
> situation is that the US doesn't tax Apple's money in Ireland because the
> money belongs to an corporation incorporated outside the US, and Ireland
> doesn't tax it because the money is controlled from outside Ireland.
>

> And both Democrats and Republicans (with a few exceptions like Rand Paul)
> are furious with Apple because Apple is taking advantage of this situation.
> Curiously, they're not showing infuriation at other companies (e.g.,

> Microsoft and Google) for doing the same or similar things却robably because

> those other companies don't have nearly as much money involved as does
> Apple.

Like pigs at a trough. They created it they should live with it. Rand Paul
seems to be the only honest one among that bunch of low-life thieves.

BTW: Just how many years has it been that General Electric has failed to pay
taxes? You don't a peep about that.

[George Kerby]

On 5/22/13 8:04 PM, in article
ipmdnV7e68SA9gDM...@giganews.com, "Alan Browne"

BINGO!

I don't usually agree with you on much, but that was dead on accurate, Alan.
The moneychangers have to have their thieving palms greased regularly.

[George Kerby]

On 5/22/13 9:07 PM, in article
519d79f3$0$55126$c3e8da3$e408...@news.astraweb.com, "JF Mezei"

Ireland's tax rate is single digit, that is why so MANY companies park their
money there. That was pointed out in the article.

[George Kerby]

On 5/23/13 8:42 AM, in article
chine.bleu-A2903...@news.eternal-september.org, "Siri Cruise"
<chine...@yahoo.com> wrote:

> In article <CDC289B2.9C1D0%ghost_...@hotmail.com>,
> George Kerby <ghost_...@hotmail.com> wrote:
>
>> The greedy bastards make crack whores look like Mother Teresa...
>
> It's real easy. Get all the voters to agree to forego the goodies they
> themselves receive. So far voters only agree to cut the goodies someone gets
> while demanding the necessities they receive to remain place,

I have always maitained a strict Flat Tax of, say 10% on everyone. But I
know that it would never happen - too many bureaucrats would become
unemployed.

[nospam]

In article <michelle-D4F53D...@news.eternal-september.org>,

Michelle Steiner <mich...@michelle.org> wrote:

> > Ireland's tax rate is single digit, that is why so MANY companies park
> > their money there. That was pointed out in the article.
>

> Actually, it's 12%.

that's a single digit in hexadecimal. :)

[News]

On 5/23/2013 10:21 AM, Michelle Steiner wrote:

> The point that you are missing is that if Apple brought that money into the
> USA, Apple would have to pay 35% income tax on it. Therefore, keeping the
> money there does save Apple money.
>


And the point you are missing, given money is fungible, is that Apple

[JF Mezei]

On 13-05-23 10:21, Michelle Steiner wrote:

> The point that you are missing is that if Apple brought that money into the
> USA, Apple would have to pay 35% income tax on it. Therefore, keeping the
> money there does save Apple money.

If Apple makes $100 of profits in France and brings those profits to the
USA, does it still have to pay taxes for that $100 to the French
government (I use France generically here apply to any/all countries
outside the USA).

The problem here is that if those profits are "in prison" all over the
world, that amount of cash does not allow Apple to be very productive
and use it for R&D etc.

On the other hand, if Apple can use profits made in Europe to pay
Foxconn to build millions of iPhones, then Apple can make use of that
money without patriating to the USA (it isn't "repatriated" since it was
never in the USA to begin with).

My main concern is Apple having oddles of money all over the world which
is not productive.

[JF Mezei]

>> > Actually, it's 12%.

Ireland was the golden child of the european economy right up until the
bank debacle where everything unraveled, th irish government had to bail
out AIB and raise tax rates to pay for it all.

So it is quite possible that the tax rates were below 10% before 2008-2009.

It is also possible the tax rates are still lower than elsewhere.

[Kurt Ullman]

In article <519e4a77$0$43946$c3e8da3$9dec...@news.astraweb.com>,

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

> On 13-05-23 10:21, Michelle Steiner wrote:
>
> > The point that you are missing is that if Apple brought that money into the
> > USA, Apple would have to pay 35% income tax on it. Therefore, keeping the
> > money there does save Apple money.
>
> If Apple makes $100 of profits in France and brings those profits to the
> USA, does it still have to pay taxes for that $100 to the French
> government (I use France generically here apply to any/all countries
> outside the USA).

Yes, although they do get a credit for the taxes paid to the
French. So if (for example) the French charge 15% for taxes and the US
charges 35% (the alleged tax rate), APPL would have to pay $20 in taxes
on that money to bring it home (As with all things tax, this is a rather
simplistic discussion.)

>
> The problem here is that if those profits are "in prison" all over the
> world, that amount of cash does not allow Apple to be very productive
> and use it for R&D etc.
>
> On the other hand, if Apple can use profits made in Europe to pay
> Foxconn to build millions of iPhones, then Apple can make use of that
> money without patriating to the USA (it isn't "repatriated" since it was
> never in the USA to begin with).

I will defer to the linguists in this case, then. The accountants
always talk about repatriation since it is an American company bringing
profits in country (grin).
http://www.buzzle.com/articles/profit-repatriation-the-foreign-direct-inv
estment-incentive.html

>
> My main concern is Apple having oddles of money all over the world which
> is not productive.

[News]

On 5/23/2013 12:49 PM, Michelle Steiner wrote:

> In article <knles9$inm$1...@dont-email.me>, News <Ne...@Group.Post> wrote:
>
>>> The point that you are missing is that if Apple brought that money
>>> into the USA, Apple would have to pay 35% income tax on it.
>>> Therefore, keeping the money there does save Apple money.
>>
>> And the point you are missing, given money is fungible, is that Apple
>> itself says:
>>
>> "Apple said ...the existence of its subsidiary Apple Operations
>> International in Ireland did not reduce Apple's U.S. tax liability..."
>

> But moving it to the USA will increase Apple's U.S. tax liability.
> Therefore keeping it in Ireland does save Apple money.
>


So you agree that Cook "mis-spoke himself".

[George Kerby]

On 5/23/13 12:06 PM, in article
519e4cb0$0$64379$c3e8da3$5e5e...@news.astraweb.com, "JF Mezei"

My bad. It has been 12.5% since 2006 if this chart is to believed...

<http://www.kpmg.com/global/en/services/tax/tax-tools-and-resources/pages/co
rporate-tax-rates-table.aspx>

[JF Mezei]

BTW, Apple's Cook's speech at Senate:

http://images.apple.com/pr/pdf/timcookopeningstatement.pdf

[JF Mezei]

Apple's Peter Oppenhermer (CFO) statement to Senate:

http://images.apple.com/pr/pdf/oppenheimeropeningstatement.pdf

[DevilsPGD]

In the last episode of <7ZmdnS_5nIJB-gDM...@giganews.com>,
Alan Browne <alan....@FreelunchVideotron.ca> said:

>The US tax situation is so screwed up that Apple are actually
>_borrowing_ money to pay dividends to shareholders rather than bringing
>in cash from their accounts to pay the shareholders. It is cheaper to
>pay that back (at a few %) out of future cash flows from US sales alone
>than to re-patriate that cash with the current tax structure.

I've heard a theory that perhaps Apple has an arrangement with the bank
where they can borrow domestically but repay internationally, which
would leave the tax problem in the hands of the bank instead of Apple.

Since banks specialize in money and ignoring laws to get richer, they're
probably happy to do the dirty work, leaving Apple's hands clean in the
process.

However, the borrowing scheme might make sense even if they can't make
anything like this actually work, if only because having some debt on
the books can be advantageous when it comes to tax time.

--
The nice thing about standards, there is enough for everyone to have their own.

[Tom Stiller]

In article <519e4a77$0$43946$c3e8da3$9dec...@news.astraweb.com>,
JF Mezei <jfmezei...@vaxination.ca> wrote:

Why is that *your* concern?

--
PRAY, v. To ask that the laws of the universe be annulled in behalf
of a single petitioner confessedly unworthy. -- Ambrose Bierce

[Bert]

In news:csnsp8h03cacfem03...@4ax.com DevilsPGD

<booga...@crazyhat.net> wrote:

> Since banks specialize in money and ignoring laws to get richer,

Have you informed the authorities about these banks?

--
be...@iphouse.com St. Paul, MN

[Alan Browne]

On 2013.05.22 22:07 , JF Mezei wrote:
> On 13-05-22 21:56, Michelle Steiner wrote:
>

>> It obviously saves Apple lots of money because if Apple brought that money

>> into the USA, Apple would have to pay 35% income tax on it.
>

> Not that simple. When Apple <country> keeps the money, it is likely they
> have to pay local taxes on those profits.
>
> Depending on the country, if they repatriate the money, they don't have
> to pay local taxes because they end up paying taxes in USA.
>
> But in other places, they would end up paying txes twice on it, once in
> the origial country and once when patriated to the USA.

Not that simple either - then you get into tax treaties between
countries that purportedly avoid companies being double taxed (or at
least not excessively double taxed).

But that still doesn't help Apple for a lot of its cash so it goes
looking for max protection.


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

[Jolly Roger]

In article <CDC289B2.9C1D0%ghost_...@hotmail.com>,
George Kerby <ghost_...@hotmail.com> wrote:

> The greedy bastards make crack whores look like Mother Teresa...
>

> <http://www.forbes.com/sites/johntamny/2013/05/22/apple-ceo-tim-cook-pounds-
> another-nail-into-the-keynesian-coffin/?partner=yahootix>

I stooped at the third mention of Keynes. What a load of political
whiney bullshit.

--
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

[Jolly Roger]

In article <PJudnZvdlvmE_ADM...@earthlink.com>,
Kurt Ullman <kurtu...@yahoo.com> wrote:

> In article <michelle-D863D4...@news.eternal-september.org>,
> Michelle Steiner <mich...@michelle.org> wrote:
>
> >
> > The problem is not that Apple is hoarding money overseas�it's not that
> > Apple is hoarding money�the problem is that the tax laws are so messed up.

> > Apple is not at fault for taking advantage of those tax laws as they exist.
>
> SOmeone noted the dichotomy (although I might upgrade it to hypocrisy)
> of individuals being exhorted to find every deduction that you are
> legally entitled to, but for some reason Corps aren't supposed to do the
> same thing.

The reason is this government is corrupt at every level, and laws have
been designed to favor corporations and bankers over the real people of
the United States.

[Jolly Roger]

In article <michelle-6108E8...@news.eternal-september.org>,

Michelle Steiner <mich...@michelle.org> wrote:

> In article <PJudnZvdlvmE_ADM...@earthlink.com>,
> Kurt Ullman <kurtu...@yahoo.com> wrote:
>
> > > The problem is not that Apple is hoarding money overseas�it's not that
> > > Apple is hoarding money�the problem is that the tax laws are so messed
> > > up. Apple is not at fault for taking advantage of those tax laws as
> > > they exist.
> >
> > SOmeone noted the dichotomy (although I might upgrade it to hypocrisy)
> > of individuals being exhorted to find every deduction that you are
> > legally entitled to, but for some reason Corps aren't supposed to do the
> > same thing.
>

> The problem isn't in finding deductions; it's in finding loopholes. The
> situation is that the US doesn't tax Apple's money in Ireland because the
> money belongs to an corporation incorporated outside the US, and Ireland
> doesn't tax it because the money is controlled from outside Ireland.
>

> And both Democrats and Republicans (with a few exceptions like Rand Paul)
> are furious with Apple because Apple is taking advantage of this situation.
> Curiously, they're not showing infuriation at other companies (e.g.,
> Microsoft and Google) for doing the same or similar things�probably because
> those other companies don't have nearly as much money involved as does
> Apple.

Not to mention Walmart, the banks, etc. Lame.

[Jolly Roger]

In article <519e4a77$0$43946$c3e8da3$9dec...@news.astraweb.com>,
JF Mezei <jfmezei...@vaxination.ca> wrote:

No, your main concern is trolling Apple as much as possible.

[Jolly Roger]

In article <michelle-09BD2A...@news.eternal-september.org>,

Michelle Steiner <mich...@michelle.org> wrote:

> In article <knles9$inm$1...@dont-email.me>, News <Ne...@Group.Post> wrote:
>

> > > The point that you are missing is that if Apple brought that money
> > > into the USA, Apple would have to pay 35% income tax on it.
> > > Therefore, keeping the money there does save Apple money.
> >
> > And the point you are missing, given money is fungible, is that Apple
> > itself says:
> >
> > "Apple said ...the existence of its subsidiary Apple Operations
> > International in Ireland did not reduce Apple's U.S. tax liability..."
>

> But moving it to the USA will increase Apple's U.S. tax liability.
> Therefore keeping it in Ireland does save Apple money.

semantics

ho hum

[AV3]

On May/23/2013 12:4902 PM, Michelle Steiner wrote:

> In article<knles9$inm$1...@dont-email.me>, News<Ne...@Group.Post> wrote:
>
>>> The point that you are missing is that if Apple brought that money
>>> into the USA, Apple would have to pay 35% income tax on it.
>>> Therefore, keeping the money there does save Apple money.
>>
>> And the point you are missing, given money is fungible, is that Apple
>> itself says:
>>
>> "Apple said ...the existence of its subsidiary Apple Operations
>> International in Ireland did not reduce Apple's U.S. tax liability..."
>

> But moving it to the USA will increase Apple's U.S. tax liability.
> Therefore keeping it in Ireland does save Apple money.
>

Actually, the money is in no-tax Bermuda. Tim Cook was weasely, when he
said Apple didn't bank in the Caribbean, since it does business with
just such a bank singularly in mid-Atlantic. And that "Irish"
corporation AOI has three directors, all Apple employees, one Irish and
the other two American. Its board has taken to meeting exclusively in
Cupertino and the Irish "board member" doesn't attend. It is manifestly
a fraud and might be subject to current law, but there is no way of
getting at its assets, so it is not worth prosecuting.


I don't mean to be attacking just Apple. "Sixty Minutes" had a program
about American corporations with sham offices all in the same building
in Switzerland, all served by a single "receptionist," who directed
inquiries to the home offices in America. Swiss law eventually required
the corporations to send some executives to take up part-time residence
in Switzerland, which they did.


--
++====+=====+=====+=====+=====+====+====+=====+=====+=====+=====+====++
||Arnold VICTOR, New York City, i. e., <arvi...@Wearthlink.net> ||
||Arnoldo VIKTORO, Nov-jorkurbo, t. e., <arvi...@Wearthlink.net> ||
||Remove capital letters from e-mail address for correct address/ ||
|| Forigu majusklajn literojn el e-poŝta adreso por ĝusta adreso ||
++====+=====+=====+=====+=====+====+====+=====+=====+=====+=====+====++

[DevilsPGD]

In the last episode of <XnsA1C9D430D76...@78.46.70.116>, Bert

<be...@iphouse.com> said:

>In news:csnsp8h03cacfem03...@4ax.com DevilsPGD
><booga...@crazyhat.net> wrote:
>
>> Since banks specialize in money and ignoring laws to get richer,
>
>Have you informed the authorities about these banks?

Attorney General Eric Holder is aware of criminal activity by the banks,
but chooses to not pursue charges:

http://www.salon.com/2013/03/07/holder_banks_too_big_to_prosecute/

| The Justice Department has not brought a single criminal conviction
| against a Wall Street executive four years after a financial crisis
| proven to have been precipitated by fraudulent behavior. On Wednesday,
| Holder admitted that the vast size of major banks and the structural
| integration in the economy makes criminal prosecutions basically
| impossible.

If you can suggest an authority who might actually take action, I'd be
interested, but generally the Attorney General of the United States is
pretty much the last stop, at least in the US.

[JF Mezei]

On 13-05-23 14:42, Tom Stiller wrote:

> Why is that *your* concern?

As an AAPL shareholder, the inability of Apple to use its foreign money
concerns me because they can't give it back to me as dividends

Note that in Apple's statement to senate, they did confirm that Apple
Ireland "buys" R&D services from Apple USA. (in essence partly funding
Apple's R&D efforts).

This does alleviate some of the concerns of foreign cash isn't helping
Apple develop.


At the end of the day though, it would be more efficient for AAPL (the
corporation) to be headquartered in Ireland. This way, it could draw
from all fo its cash reserves to issue dividends.

I do not believe in a company borrowing money to issue dividends. This
is not a sustainable practice. And it was perhaps done as a "coup" to
show senators how stupid the USA laws are. Hopefully this is a one time
event.

[JF Mezei]

As a shareholder, Apple's Irish money is like the gold aboard a sunken
ship. It is there, but nobody can get to it. It doesn't benefit me.

I benefit more if Apple pays for salvage even if it means 35% of gold is
lost. At least 65% of that gold can be distributed whereas now, 0% can.

Onr possibility would be for Apple to spin off 49% of Apple Ireland and
give those shares to existing AAPL shareholders. So one would own AAPL
and AAPL2 shares. Apple Ireland could issues dividends without paying
taxes to USA.

Heck, Apple might structure the shares so that it own 100% of voting
rights but 0% of dividends, this way none of the Apple Ireland dividends
would go back to Apple USA (which would then be taxed).

Alternatively, the USA should allow a corporation to patriate tax-free
sums that are going directly to shareholders as dividends. (since
shareholders have to pay income tax on dividends anyways).

[Alan Browne]

On 2013.05.23 19:15 , JF Mezei wrote:
> On 13-05-23 14:42, Tom Stiller wrote:
>
>> Why is that *your* concern?
>
> As an AAPL shareholder, the inability of Apple to use its foreign money
> concerns me because they can't give it back to me as dividends

1. They are giving back dividends. Indeed they are borrowing to do so.

2. Whatever they do not give back in dividends remains reflected in the
stock price.

3. As an additional bonus to you they are buying back shares from the
market to an astounding $60B. That will simply increase the value of
shares you choose to not to sell.

4. And to make it sweeter still, they've increased the dividend per
share going forward so you're getting cash out that you did not expect
when you bought your shares.

> I do not believe in a company borrowing money to issue dividends. This
> is not a sustainable practice.

Who said it needs to be sustainable? It only needs to last for the next
two and a half years under the current capital return program.

Apple's credit rating is very high so they negotiate the very best
commercial rates. Then they take the repayments out of future cash
flows and reduce the amount of cash they have to stuff in the low
interest bearing mattress.

It is in your best interest that they do so - because if they repatriate
the cash it will take a tax hit and there will be less capital left in
the company (that remains part of your share price).

(I should just say: the bean counters computed the cheapest way to get
you your dividend so shut up and be happy).

[Alan Browne]

On 2013.05.23 19:38 , JF Mezei wrote:


It's really irritating when you reply w/o attribution or some snippet of
what you're replying to.

[JF Mezei]

On 13-05-23 19:55, Alan Browne wrote:

> It's really irritating when you reply w/o attribution or some snippet of
> what you're replying to.

If I am not replying to anyone and just adding to the discussion, there
is no need to quote or provide attribution. (as in the case of the
links to the apple web site for the speeches by Cook/openheimer to the
US Senate).

[George Kerby]

On 5/23/13 6:02 PM, in article 8j7tp8p6gpbmn071b...@4ax.com,

"DevilsPGD" <booga...@crazyhat.net> wrote:

> In the last episode of <XnsA1C9D430D76...@78.46.70.116>, Bert
> <be...@iphouse.com> said:
>
>> In news:csnsp8h03cacfem03...@4ax.com DevilsPGD
>> <booga...@crazyhat.net> wrote:
>>
>>> Since banks specialize in money and ignoring laws to get richer,
>>
>> Have you informed the authorities about these banks?
>
> Attorney General Eric Holder is aware of criminal activity by the banks,
> but chooses to not pursue charges:
>

Holder needs to worry about his own ass. Between gun-running in Mexico and
the latest scandals, he should be sent to Club Fed.

[George Kerby]

On 5/23/13 6:15 PM, in article
519ea324$0$28653$c3e8da3$f017...@news.astraweb.com, "JF Mezei"

<jfmezei...@vaxination.ca> wrote:

> On 13-05-23 14:42, Tom Stiller wrote:
>
>> Why is that *your* concern?
>
> As an AAPL shareholder, the inability of Apple to use its foreign money
> concerns me because they can't give it back to me as dividends
>

SELL, SELL, SELL...

Cut off your nose to spite your face.

[News]

Right after every 501c4 scammer.

[AV3]

On May/23/2013 10:3622 PM, Lewis wrote:
> In message<519ea324$0$28653$c3e8da3$f017...@news.astraweb.com>

> JF Mezei<jfmezei...@vaxination.ca> wrote:
>> On 13-05-23 14:42, Tom Stiller wrote:
>
>>> Why is that *your* concern?
>
>> As an AAPL shareholder, the inability of Apple to use its foreign money
>> concerns me because they can't give it back to me as dividends
>

> Well, that is obviously not true.

>
>> At the end of the day though, it would be more efficient for AAPL (the
>> corporation) to be headquartered in Ireland. This way, it could draw
>> from all fo its cash reserves to issue dividends.
>

> If that were the case, a lot fo companies would be headquartered in
> Ireland. They are not, therefore your belief is certainly wring.
>


They don't need their headquarters in Ireland, just an affiliated
corporation. That is Great Britain's complaint against Google: Google's
British affiliate paid an inordinate amount of money for some before-tax
nebulous debt to its Irish affiliate, leaving little to tax back in
Great Britain and little to tax in Ireland. Apple's Irish affiliate is AOI.


>> ...

[Jolly Roger]

In article <519ea868$0$5842$c3e8da3$5077...@news.astraweb.com>,

So we should cater to greed. Got it.

[Jolly Roger]

In article <519ea324$0$28653$c3e8da3$f017...@news.astraweb.com>,

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

> On 13-05-23 14:42, Tom Stiller wrote:
>
> > Why is that *your* concern?
>
> As an AAPL shareholder, the inability of Apple to use its foreign money
> concerns me because they can't give it back to me as dividends
>
> Note that in Apple's statement to senate, they did confirm that Apple
> Ireland "buys" R&D services from Apple USA. (in essence partly funding
> Apple's R&D efforts).
>
> This does alleviate some of the concerns of foreign cash isn't helping
> Apple develop.
>
> At the end of the day though, it would be more efficient for AAPL (the
> corporation) to be headquartered in Ireland. This way, it could draw
> from all fo its cash reserves to issue dividends.

Translation: "I don't give a shit about the company itself - just their
money."

Thank goodness you aren't representative of all AAPL shareholders.

[Kurt Ullman]

In article <jollyroger-DAA94...@news.individual.net>,

Jolly Roger <jolly...@pobox.com> wrote:

> > Alternatively, the USA should allow a corporation to patriate tax-free
> > sums that are going directly to shareholders as dividends. (since
> > shareholders have to pay income tax on dividends anyways).
>
> So we should cater to greed. Got it.

Actually I would suggest we should do everything we can to tax
advantage dividends. Dividend paying stocks, even over the last few
years, have still done better than those without. Dividends are going to
become more important to us oldsters who need additional income as we
age and retire. You can't restate a dividend. The metrics of dividend
stability are much easier to figure out and much less subject to gaming.
--
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]

In article <p42dnUILCcnYbALM...@earthlink.com>,

Kurt Ullman <kurtu...@yahoo.com> wrote:

> In article <jollyroger-DAA94...@news.individual.net>,
> Jolly Roger <jolly...@pobox.com> wrote:
>
> > > Alternatively, the USA should allow a corporation to patriate tax-free
> > > sums that are going directly to shareholders as dividends. (since
> > > shareholders have to pay income tax on dividends anyways).
> >
> > So we should cater to greed. Got it.
> Actually I would suggest we should do everything we can to tax
> advantage dividends. Dividend paying stocks, even over the last few
> years, have still done better than those without. Dividends are going to
> become more important to us oldsters who need additional income as we
> age and retire. You can't restate a dividend. The metrics of dividend
> stability are much easier to figure out and much less subject to gaming.

And to follow up, dividends (to the extent they are reinvested) work
like regular savings with compounding. Also as the dividend goes up, so
does your yield. A couple stocks I have owned for a long time have a
yield based on current price of around 1. or 2 %. But the yield based on
what I actually paid for them means I am getting 10% on my money (plus
the cap gains should I take them).
The S&P 500 lost less than 1% even during the 2000s on a total
return basis (compared to nearly 3% loss on a price-only basis. Thus
dividends are your friends.

[Bert]

In news:knns2j$aq3$1...@dont-email.me News <Ne...@Group.Post> wrote:

> Right after every 501c4 scammer.

You're aware of 501(c)(4) "scammers?"

Have you informed the IRS? There's probably a bounty paid to snitches
like you.

[News]

On 5/25/2013 12:16 PM, Bert wrote:
> In news:knns2j$aq3$1...@dont-email.me News <Ne...@Group.Post> wrote:
>
>> Right after every 501c4 scammer.
>
> You're aware of 501(c)(4) "scammers?"
>
> Have you informed the IRS? There's probably a bounty paid to snitches
> like you.
>

If you have nothing to hide, you have nothing to worry about.

So, do you feel lucky, scammer?