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With $160 Billion Merger, Pfizer Moves To Ireland and Dodges Taxes (arstechnica.com)
ourlovecanlastforeve writes: In a $160 billion dollar acquisition, drug company Allergan, a small company based in Ireland, "purchased" Pfizer, allowing the drug producing giant to move to Ireland and lower its tax rate from about 25 percent to 17-18 percent. Ars reports: "Such inversions, which are said to cost the American government billions in lost tax revenue, have drawn scorn from the Obama Administration and the Treasury Department. Last year, President Obama referred to the deals as 'unpatriotic' loopholes and proposed to close them. And last week, the Treasury announced new rules to make such deals more difficult. But Pfizer’s reverse-inversion skirts the rules, in part by keeping ownership split somewhat evenly between the two companies. After the deal is complete, current shareholders of Allergan, which has the majority of its operations in the US, will own 44 percent of the mega company. The remaining 56 percent will be owned by current Pfizer shareholders."
America should be punished for having such a ridiculous tax code and a confiscatory corporate tax rate. I'd also move my operation to Ireland if I could.
How about we just lower our tax rate to 15%? We would then be a favorable place to have business and while not cashing in on $0 at the higher rate we would at least cash in on some taxes.
Forbid Medicare and Medicaid payments to companies that choose to move headquarters for the purpose of avoiding US tax. Maybe that will cause them to change their mind.
if you believe all income belongs first to the state. All this is legal, and the whining that inevitably goes on after such transactions reflects the belief that the "fair share" of a corporation's income is less than whatever the speaker wants it to be.
Dog is my co-pilot.
his new tax plan SAVES AMERICANS BILLIONS AND BILLIONS OF DOLLARS and trump is a finance man, he went to warton school of business, one of the hardest schools, he will MAKE JAPAN PAY FOR ITS PROTECTION. And the japanese will love america. TRUMP 2016.
Hardly a small company in Ireland... Maybe smaller than Pfizer, but not by much.
....when you have the most insane corporate tax rate in the world.
Good on them, I reckon.
Ferret
Sic gorgiamus allos subjectatos nunc
until our politicians wake up and realize all costs are pushed onto the consumer anyway nothing will change
its not a "loophole" its the law, and until the law is favorable to business, business will continue to move to places that are business friendly. We see it on a microscale in the USA as it is, look at all the companies who are based in delaware.
Delaware is only for corporate law adjudication. Taxes are still collected for revenue or operations in other states (i.e., if you have a footprint or customers there, you still pay).
Make sure everyone's vote counts: Verified Voting
One of the more funny off topic variations.
The solution has already been implemented for the individual, and should be evenly applied to corposrations, after all they make use of the infracstructure that has been largely funded by public dollars such as highways, laws--especially Intellectual Property laws, Law enforcement, military and security to pretect your assets and investments, communications infrastructure, etc.
As an individual if you accrue income overseas, you are still responsible for filing US taxes, even if you are not a US resident at the time the income was accrued. There is a credit granted to you for the amount of taxes payed elsewhere, however if the foreign taxes are less than the US taxes, you still pay.
Corporations should be liable for the same debt. That way, if they wish to take advantage of all of the public infrastructure present in the USA, then they are responsible for paying their fair share of taxes.
when Ireland drops theirs to to 10%? I guess we could do 5%. Then they'd do 2 and a half, then we'll do 1 and they'll do -5% (e.g. incentives) and we can top that with -10%....
See, this is what's called a "Race to the Bottom". The correct response is to tell Phizer: Thanks, and by. Then you slap a 50% tarriff on their drugs and enforce strict price controls. If that doesn't work you take their patents from them. If they stop "innovating" then fine. We hire folks to innovate in their place and tell them to go pound sand. What you do _not_ do is let them control negotiations and play their game. You will lose sir.
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It doesn't even qualify as news that matters
They were just fleeing an oppressive government in search of a better life!
It seems like if we had any sense at all, we'd immediately dump the corporate income tax and replace it with a revenue-neutral increase in the capital gains and dividend taxes. The corporate shareholders ultimately end up paying any dollars that get paid anyway, and humans are much easier to tax than corporations are. A corporation is a shape-shifting non-entity that can "spend a year dead for tax purposes," so trying to change the laws fast enough to get any revenue out of them is a losing battle. All we end up doing is giving them an incentive to do ridiculous things like hold money in foreign accounts and set up subsidiaries all over the world to move revenue around. It's great for the tax lawyers and financial consultants, but it doesn't really get us any real revenue. It's the tax enforcement equivalent of the drug war.
An interesting anagram of "BANACH TARSKI" is "BANACH TARSKI BANACH TARSKI"
I'd also move my operation to Ireland if I could.
What's stopping you?
The US tax code. The US keeps its hooks in its citizens and companies, for decades, if they try to leave, even if they move out and renounce their citizenship.
The US does this to a far greater extent than other countries who generally don't tax their citizens if they're out of the country for more than half a year. (This is where "The Jet Set" came from: Citizens of various non-US countries who had found a way to earn a living that let them split their time among three or more countries every year and avoid enough income tax to live high-on-the-hog, even on an income that otherwise might be middle-class.)
Only really big companies, with armies of lawyers, can find loopholes that let them effectively move out of the US to a lower-taxing alternative. You'll note that TFA is a lament about how one managed to escape, and how the US might "close THIS loophole" to prevent others from using it.
Bantam Dominique roosters crow a four-note song. Once you've heard it as "Happy BIRTHday" you can't NOT hear it that way
Trump will make AMERICA GREAT AGAIN. He is TOP 1 OF THE ECONOMY POLLS. the press don't talk about it because they are all liars. The press are such disgusting people. Not all of them, but 70% of them. TRUMP is so great, he will be such a great president. All the other candidates pay this and that, TRUMP only pays a little, and gets much higher polls than the others. TRUMP WILL MAKE AMERICA GREAT AGAIN.
Trump will LOWER THE TAXES IN AMERICA, and make ireland pay for the tax difference. BECAUSE TRUMP IS SO GREAT IRELAND WILL LOVE TRUMP AND THE US.
Trump 2016
How about we lower taxes to a reasonable level so that companies don't feel the need to do this?
and he's going to close those loopholes. America will be made great again.
As Obama sits on his high horse, claiming such deals are "unpatriotic", I am reminded that the current tax code - the set of rules that makes all of this perfectly legal - was crafted by Congress. The very same congress that is screaming bloody murder when corporations utilize these laws to their advantage. I am also reminded of the legalized bribery...oops...I mean lobby groups...that leaned on congress to pass such laws.
Congress creates a problem...then steps in and attempts to fix it...thereby making it even worse than it was in the first place. Lather, rinse, repeat.
This is the same congress that handed out billions of dollars of taxpayer money - our money - to failing banks with no strings attached. Then they complained because the banks turned around and gave their executives fat bonuses - again, our money - because congress was too stupid to forbid them from doing that.
There are many,many, many examples of this kind of fraud, abuse and incompetence in the US government. And that, ladies and gentlemen, is why Obama Care is going to fail. And every other big government program for that matter.
Smaller government is the only answer to this. The more money we throw at these big problems the worse it gets.
You want to stop these corporate inversions? Get rid of the IRS as we know it and replace it with a flat tax. No more deductions, loopholes, etc. No more gaming the system. No more bribery. If a corporation tries to pull what Phizer is doing then fine, you are now a foreign corporation and subject to import duties. And that incorporation in Delaware? You can forget about that too because it only applies to US based companies. Just watch how quickly they all fall in line.
For the billions currently stashed in other countries you offer a one time 10% tax on repatriated funds. Then you take that money and shore up the social security trust fund. Anything left gets rebated to American taxpayers. Above all else, you keep congress and their sticky fingers away from the money.
Trump will stop corporate inversions. Trump will bring back the taxes, he will bring back the jobs, and he will LOWER THE TAXES.
All those low energy candidates can't fight as hard for DEALS as trump can do it.
Trump 2016
TRUMP will REPEAL AND REPENT the tax code. Don't listen to that woman, she ruined HP. Trump will make a far greater tax plan than her "three pages" plan.
TRUMP 2016
This is pretty bold (not really the right word) of Pfizer to move overseas, considering that they, along with the rest of big Pharma are the ones who lobbied to make it illegal for Americans to import cheaper prescription drugs. Maybe Pfizer should be required to sell their drugs in the USA for the price they charge in Ireland.
15% Flat rate would level playing ground and make it equal for both individuals, corporations both large and small.
Reality is that Corporations dont like of competition, because middle class is paying upwards of 48% marginal tax (state plus federal plus medicaid/medicare etc).
An interesting anagram of "BANACH TARSKI" is "BANACH TARSKI BANACH TARSKI"
That's the best sig I've seen in quite awhile.
It's not illegal, so Obama needs to shut the fuck up about what's 'patriotic'.
The government writes the rules; if they're too stupid to write rules that aren't gameable, they're idiots.
If our corporate taxes are so high (the highest statutory rate in the industrialized world, and nearly the highest effective rate (2nd to New Zealand)) that businesses are driven to shenanigans like this (which certainly wasn't cost- or challenge-free for the company), then clearly our tax rate is too high.
It's TRUE globalization, kids; not only will companies go overseas to find cheaper workers if there's no added value to having some lazy American do the work, companies will go overseas if the savings found in moving offset the relative inconvenience of having their hq elsewhere.
-Styopa
Only really big companies, with armies of lawyers, can find loopholes that let them effectively move out of the US to a lower-taxing alternative. You'll note that TFA is a lament about how one managed to escape, and how the US might "close THIS loophole" to prevent others from using it.
Not really. A mid-sized company can do this with only a couple of lawyers, so long as they're good. Obviously it has to be big enough that it will save more in taxes than it costs in legal fees, costs, and goodwill.
Forbid Medicare and Medicaid payments to companies that choose to move headquarters for the purpose of avoiding US tax. Maybe that will cause them to change their mind.
You're thinking too small and you're risking a lot of lives. Don't forbid the payments; threaten the underlying patents.
and China still uses them to protect their native industry. But sure, dismiss them outright because of... reasons? Anyway your post is kind of a lousy troll, but I'll address the main point, which is that repatrioting cash is a good thing. Thing is, I don't care. America has plenty of resources and wealth. Their "cash" only has value because we say it does. Let 'em keep it and we'll tax their wealth to fund the society they benefit from. Problem solved, again.
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If consumers are free to make choices, retailers must keep their prices reasonably low in order to keep customers from fleeing to the competition.
That's a good thing.
You may not like to hear it, but this is also a good thing:
If businesses are free to make choices about where they will operate, governments must also keep their tax rates reasonably low in order to keep businesses from fleeing to other jurisdictions.
What do you do when tax rates become negative, you ask? That would be analogous to a retailer that permanently operates on negative profit margins. Funny, when my local gas stations compete with each other on price -- which is to say, always -- they never engage in such a "race to the bottom."
That that is is that that that that is not is not.
I think this tax heaven thing will come to an end one day and they will suffer the consequences.
Gotta understand the decision-making process for politicians:
1) These companies are big donors.
2) 90% percent of the population has no idea about this, and fewer care.
3) Politicians get cash for looking the other way, and it has no impact on their electability.
I started following these kinds of shenanigans prior to the financial crisis. The blame is on the politicians - not for being self interested, but for actually undermining the society for cash and favors from big donors. The vast majority of the voting public doesn't understand this kind of inside baseball. And the incumbency rate hasn't really changed much as a result of these issues. So the boiling of the frog (this society) will continue until we become Brazil or we snap out of the torpor.
"A society cannot be both ignorant and free." -- Lady Gaga
We can fix this problem and get patent reform at the same time.
After 3 years, patents issued to foreign based or owned companies can't be enforced against US owned companies making products in the US that utilize them. Patents issued to American owned companies using the patent to make a product in the US can enforce them for the normal time against anyone.
This solves the problem with obnoxious multi-nationals hoarding patents by making them only useful for a very short time. It discourages US companies from "inverting" for tax purposes but largely remaining American corporations (and thus benefitting from taxpayer provided legal, diplomatic and protection but skipping out on the taxes). And it encourages businesses to make products in the US.
Of course companies with insanely good and hard to make products may choose not to sell them here because of this, but the upside is there'd be an incentive and means to make them here by other means and for the most part, willfully refusing to sell in the American marketplace is like throwing money away.
There's no reason that the patent system couldn't be used as a tool to encourage business in America and discourage evading paying for the very civil society that makes business work. Hopefully now Pfizer will be utilizing the vast resources, long reach and deep influence of the Irish government to enforce their patents, lobby governments when they don't get the treatment they want, when, say a new drug is copied in China or India or when the FDA doesn't approve it.
When TRUMP is elected, America will win so much, we will get tired of winning!
Actually, the opposite is true: it's the high tax welfare state that has come to an end in Ireland and that they suffered the consequences of. They have now come to their senses. The US will sooner or later have to follow suit.
when you have practical monopolies created when a small group of people own everything. Try to find something in your house you use day to day that isn't made by one of the Koch Brothers companies for instance. Played any of the Saints Row games? They own those (among others). You Toilet paper was probably made by them (there's a joke in there somewhere) and a lot of your food. Plus a tonne of your energy/oil.
Also for medical care you're not really free to make choices. For one thing without 6-10 years of study you don't really have enough information. For another thing if you have cancer and need chemo you're not exactly free to say no. This is a classic mistake folks make. You're comparing the decision making processes of buying a twinkie to the process of buying a heart transplant. While you might technically be 'buying' both, the processes are really nothing alike, and frankly you wouldn't want them to be.
Tax rates can be negative if the money comes somewhere else. Think of a retailer running scams. He doesn't scam his big clients because they will sue him or send thugs around to hurt him and his family. So he scams his little clients. Basically you and I pay our taxes so the big guys that own everything can own everything.
Now, I can already here you railing against taxes again so I'll say this: It's OK to pay taxes (render unto Caesar, yadda, yadda, yadda) , as long as you're getting something for it. What I hate about being an American is that I pay about the same a Europeans but without the free health care, social safety net and economic policies that raise my wages...
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I'm all for a reasonable tax on corporations, but not by offloading their tax burden onto the rest of us. I'm in the 25% bracket and make no where NEAR what a corporation does. Perhaps as an incentive, allow business to claim a tax deduction for money they put back into the business ? Might even get the big ISP types to upgrade their networks :|
yes, revise the U.S. tax code - like politicians will ever do that ...
a less knee jerk/punish big corporations perspective in the WSJ:
It ain't what they call you. It's what you answer to. http://mylyceum.us/
most of the hard work is done by gov't researchers. That's the "basic" in basic research. Guys like Phizer mostly just run some cheap clinical trials based on the work done by the gov't. That's because basic research is really, really expensive and often doesn't pay off for decades if ever.
/., they're too busy winning...
Labor Mobility is a fancy way to say social unrest. I think it's already been pointed out here but you can't base a stable society on folks who don't have reliable jobs. It quickly becomes impossible to raise children and the entire thing goes to hell. Profits don't though, you're right about that. If your only goal is profit without a single thought to the real human suffering your causing then you're right.
You're last comment reads like troll bait. I have no delusions though. I think we're well and proper screwed by folks like yourself. I think you're screwed too. You think you'll be the winner in "winner take all". Thing is, winners don't usually waste time posting on
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You can renounce citizenship, that solves the tax problem.
But for these corporations, they're not really leaving the US. They're just moving papers overseas. The CEOs are not uprooting their families and immigrating to somewhere else. It's only that the new parent company is in Ireland, a sleight of hand with the taxes.
We will win luxuriously. Atlantic Cities for everyone!
If you have over $2 million in total assets, the Federal Government will demand a slice of that before you can expatriate. Yes, those are accumulated assets that have already been taxed when first gained. Renouncing really doesn't solve the problem...
Browsing at +1 - no ACs, I ignore their posts. So refreshing!
Citation? Because I don't think it works like that. I think that you get taxed on unrealized (and hence untaxed) gains, but you also get to deduct the first $600k. This also applies to green card holders who leave the USA.
The real "Libtards" are the Libertarians!
Cool! The expatriation tax is up to 40% - I guess you don't mind taking about half of everything you have and just giving to the Government? In much of the world (like Europe, much of Asia, and other places) $2 million in total assets isn't that much. In fact, it's not much in the US either - own a home in the Bay area? You have assets most likely close to, if not over, the $2 million mark. This is total assets, not just cash or cash equivalents. Retirement accounts, stock options, real estate, cars, collectibles, interest in family businesses, etc.
Browsing at +1 - no ACs, I ignore their posts. So refreshing!
The IRS overview of the expatriation tax. If your total assets - cash, retirement accounts, property, stock options, etc - adds up to over $2 million and you want to renounce your citizenship, the IRS can and will tax up to 40% of your total asset accumulation. It really covers pretty much all your assets - and you don't get to claim the personal residence deduction of the first $250K (or $500K for a married couple) either for this tax.
Browsing at +1 - no ACs, I ignore their posts. So refreshing!
My Mom died of cancer because of smoking. Pfizer has nothing to help with that. I've got other family with naturally occurring cancers that can (and were) be cured by meds. Pfizer didn't make any of those. They were developed in Europe by their governments because there was no money to be made off them. Don't worry 'bout my Mom, it was years ago (she died young, Cigarettes do that to you) or my other family member who the European gov't saved.
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how easy it is to get out of taxes when you own the gov't. Right now they're putting a little effort in. As they get more and more power (because your giving it to them) they'll cut back and back.
Taxes are a powerful tool to drive certain types of behavior. They're often the only tool we have and the only real power the masses can exact on our corporate overlords. You don't leave a tool that powerful lying dormant. Well, you can, but you won't last long if you do...
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1. The $2M sum is only a test for eligibility.
2. Tax is payable on unrealized gains, not total assets:
There is a $680k deduction, which is unrelated to any primary residence:
The real "Libtards" are the Libertarians!
You've provided reasonable links, but you simply haven't read that information correctly. Here's how the U.S. Expatriation Tax actually works (assuming your net worth exceeds $2 million or that you otherwise are subject to the Expatriation Tax), oversimplifying only slightly:
1. Take your total worldwide net worth at fair market value as if all your assets were sold the day before your expatriation date.
2. Subtract your total worldwide cost basis from your net worth. The result is your total gain from your mark-to-market "deemed sale."
3. Subtract $690,000 (tax year 2015, adjusted annually for inflation) from your total gain. The result is your total taxable gain. If your total taxable gain is zero or negative, stop: you do not owe any Expatriation Tax.
4. Otherwise, pay ordinary capital gains tax rates on your total taxable gain, with a current top marginal tax rate of 23.8% (if the NIIT applies, and I'm not sure it does, but let's assume that). This is your total U.S. Expatriation Tax.
If you owe Expatriation Tax your cost basis is reset. Any subsequent capital gains on U.S. assets will only be taxed based on your new, reset cost basis. Note that "wash sale" rules do not apply when making the Expatriation Tax calculation, so deemed sale capital losses are not limited within the calculation. To some degree you can pay your Expatriation Tax in installments if you wish and only pay statutory interest on deferred payments (currently 3%). If your assets are generating a higher after-tax rate of return (quite likely) then stretching out your Expatriation Tax payment to the maximum extent allowed by law is a good idea. You may also wish to stretch out your Expatriation Tax payments if you prefer to raise funds more slowly, perhaps as in the form of interest, dividends, royalties, and/or earned income.
The U.S. Expatriation Tax is not a hardship by any reasonable definition of hardship, and it's quite disingenuous to complain about not getting a $250,000 capital gains exclusion on a home when you're getting a $690,000 blanket exclusion. But if it were a hardship, there's a simple, 100% effective solution to avoid the U.S. Expatriation Tax: don't renounce or relinquish U.S. citizenship.
One further point. I'm implicitly assuming long-term capital gains tax rates, and that's a reasonable assumption when oversimplifying slightly. For the record, short-term holdings (assets held less than one year) can get taxed at ordinary income tax rates. The top marginal U.S. income tax rate is currently 43.4% inclusive of the Net Investment Income Tax (NIIT) if it applies. However, short-term holdings presumably haven't gained as much value as long-term holdings, especially in the aggregate, unless you've been particularly lucky. And there's a simple solution for that, too: wait until the short-term holdings become long-term holdings (held for one year), then expatriate.
;) You've got to be solidly within the top 5% on a wealth basis to get to an Expatriation Tax calculation, never mind actually owing any Expatriation Tax. And then, if you do pay some, you're resetting your cost basis anyway. You're just paying Uncle Sam what you would have paid when you sold the assets, less a blanket exemption. That's quite fair when checking out permanently, just as you must settle your hotel bill and minibar tab when you check out of a hotel.
These are not exactly middle class problems, are they?
we've only been paying taxes as we know them for 100 years, since the treasonous federal reserve was created by the treasonous Woodrow Wilson, who stated he feared he "sold out his country to a few wealthy bankers".
You have no idea about history and have been mind controlled by your Rothschild controlled media, which is a small group who has control of every single news article you read.
Shut up and talk some more about cows.
I mean: the corp's tax advisors are doing their (admittedly disgusting and repugnant) job. The problem is the likes of J.C. Juncker: babbling about European Union and opening up a tax haven in the middle of it (Luxembourg). How does this filth dare to speak of "treason" (addressing Greece's prime, Tsipras)? It's Juncker who should be in jail.
Or Cameron. City of London guy (another tax haven in the middle of "civilised" Europe). No, we won't take any refugees (we'd take this one little guy on the foto, but ooooh, he's dead). But yes, we'd like to have some special treatment should we consider staying in the EU.
Know what? Good riddance, asshole.
It's the politicians (who should be representing the people, not the corps, remember?) who are either sleeping at the helm or actively damaging those they're supposed to represent.
The loophole is very easy to close: US Congress shall force POTUS to recognize the full souvereignity of Her Majesty the Queen over the rebellious island of Ireland. In exchange, Blighty transfers the full tax amount to USA.
If the catholics and the bishop of Rome do not like that, they should influence Ireland to quit cheating.
Anyhow the USA has no duties towards Ireland whatsoever, as they were allied with the german enemy both during WWI and WW2. That is inexcusable.
I'd also move my operation to Ireland if I could.
What's stopping you?
The US tax code. The US keeps its hooks in its citizens and companies, for decades, if they try to leave, even if they move out and renounce their citizenship.
The US does this to a far greater extent than other countries who generally don't tax their citizens if they're out of the country for more than half a year. (This is where "The Jet Set" came from: Citizens of various non-US countries who had found a way to earn a living that let them split their time among three or more countries every year and avoid enough income tax to live high-on-the-hog, even on an income that otherwise might be middle-class.)
Only really big companies, with armies of lawyers, can find loopholes that let them effectively move out of the US to a lower-taxing alternative. You'll note that TFA is a lament about how one managed to escape, and how the US might "close THIS loophole" to prevent others from using it.
They aren't closing a loophole they are just making a new law or promising to anyways fat chance. You don't think it was accidental that a loophole existed do you? Both sides lobby for "loopholes" that enable this completely legal move by the corporation. It didn't take a nest of lawyers burning the midnight oil to discover a way around it, it was engineered into the original law. Perhaps those who might of objected to the "loophole" were promised in kind treatment on something else completely unrelated, who knows but that's how it works.
If you want to end this then get rid of politicians, until then this behavior will always exist.
when you have practical monopolies created when a small group of people own everything.
Now you're changing the topic, which was how consumers should be able to vote with their dollars if a retailer doesn't provide good value, and citizens are better off if they're free to move to a different jurisdiction that has a better tax-to-benefits ratio than their current jurisdiction. And a business should be free to do the same. (If a business is gouged by any entity, including its government, it's bad for the little guy, because businesses always pass those costs on to their customers.)
But a consumer can't vote with their dollars if the retailer has a monopoly. And a business can't relocate if its current jurisdiction effectively has a monopoly on where that business is permitted to operate (perhaps because someone is threatening to slap a 50% tariff on its products, and/or steal its patents, if said business relocates).
So you see, when discussing the relocation of Pfizer, it's particularly incorrect to talk of monopoly. There were 193 countries, competing with various levels of effort, to get Pfizer to operate there -- the furthest thing imaginable from a monopoly. Ireland won this round, and the U.S. lost. There is a valuable lesson to be learned there, for those willing to learn it.
made by one of the Koch Brothers
Sorry, I don't buy into the fearmongering of making the Koch brothers into bogeymen. I saw an interview of Charles Koch; quite a pleasant gentleman. But apparently lots of slashdotters do buy into that fearmongering, because you got another +5 post. That's scary.
You're comparing the decision making processes of buying a twinkie to the process of buying a heart transplant.
No, I really didn't do that. The scope of my post was strictly limited to how monopolies that gouge consumers are bad, and monopolies that gouge businesses -- to include a government that doesn't allow businesses to relocate -- are also bad.
That that is is that that that that is not is not.
Companies should have every right to do this type of thing, but they should no longer benefit from the US government nor receive any protections afforded by the government beyond its US based commerce. Any portions of treaties negotiated on their behalves should be null and void, or at least should not be contested / defended if signatories wish to absolve related agreements. If there are truly no longer benefits afforded to being under the umbrella of the US and its protections, then the companies have nothing to lose.
I do somewhat sympathize as an US expat. I really hate having to deal with US taxes on my foreign income. Thankfully I live in a country that has a tax treaty in place so there is no double taxation to a certain income, so it is mostly an inconvenience of having to double file. My choice to avoid my current situation is to renounce my US citizenship. I would hesitate to do so because I value the protections and benefits keeping my citizenship affords. I suspect there would or at least should be similar considerations for a corporation. If I could simply renounce my citizenship, but receive exactly the same benefits and protections without any repercussions, why would I endure the negatives?
news at 11.
If they are no longer domiciled in the US, are they still eligible for 'personhood' as Citizens United sees it? I seem to think that foreign political contributions are prohibited, which would effectively turn their DC lobbyists into background noise. Very fitting, if so.
These days 2 million is a few houses in the burbs... It's more than I have but not the princely sum it once was...
The majority of discoveries leading to drugs sold by Pfizer were made in American labs, by Pfizer scientists. The acquisition history is varied and contains Irish, German and Canadian companies, but that's, all in all, a small portion.
If you want to be pedantic, cows are female.
"Lack of speed can be overcome. In the worst case by patience." --Znork
Trump is a COW. Cows are for Trump! Trummmmmmmp!
It takes worry, planning, and very personal care to achieve a $2 million net worth in the first place. After so much work and dedication, you do not want to see this money disappear and potentially hurt your charitable, retirement and family trust fund plans.
You should look up retirement costs. It's really expensive to live from age 60 to 90-100. You should start saving ASAP.
Parent should not be modded insightful, since the "information" given in the post is largely false.
The real "Libtards" are the Libertarians!
The U.S. Expatriation Tax is not a hardship by any reasonable definition of hardship...
It's not a question of "hardship". Stealing from people is wrong. Even when the victim has some money left over afterward.
"the secretary at MalwareBytes took a look at his source code and said it looked all good to them" - by Coren22 (1625475) on Wednesday November 18, 2015
My code went thru verification by Mr. Steven Burn of Malwarebytes' hpHosts
hpHosts Site Admin Mr. Steven Burn quoted:
"I've been asked to further clarify so for the record yes I've seen the code, and yes, it is safe."
FROM http://forum.hosts-file.net/vi...
(On my latest 9.0++ code engine above & from past versions -> http://slashdot.org/comments.p... )
A competent coder & BEST security researcher I know of FROM THE BEST ANTIMALWARE THERE IS http://www.av-test.org/en/news...
NOT a secretary!
I don't give away work to be stolen OR misused like GOOGLE CHROME http://it.slashdot.org/story/1...
---
"won't demonstrate security of his product be exposing the source" - by Coren22 (1625475) on Wednesday November 18, 2015
Bullshit: 62 reputable sources + /. users say different:
Safe by 57 antivirus programs in 64-bit model https://www.virustotal.com/en/...
+
the 32-bit model https://www.virustotal.com/en/...
&
Per VirScan (installer too)-> http://f.virscan.org/APKHostsF...
MalwareBytes' hpHosts Admin (MalwareBytes employee) hosts & recommends it -> http://hosts-file.net/?s=Downl... & MalwareBytes = BEST antivirus per this VERY recent testing of them all http://www.av-test.org/en/news...
APK
P.S.=> Eat your words, scumbag: Tell us about AD + DNS too while you're @ it & how you said I said not to run DNS when I use it myself & said to NOT use external to network DNS with AD http://slashdot.org/comments.p... - OR about how my program NEEDS admin privelege to update too (& it doesn't http://slashdot.org/comments.p... ), lol... fool - 'eat your words' on ALL those accounts chump!
... apk
Moo?
Moo!
APK likes to ask for responses to the same things over and over. Maybe he just likes the responses?
"the secretary at MalwareBytes took a look at his source code and said it looked all good to them" - by Coren22 (1625475) on Wednesday November 18, 2015
My code went thru verification by Mr. Steven Burn of Malwarebytes' hpHosts
hpHosts Site Admin Mr. Steven Burn quoted:
"I've been asked to further clarify so for the record yes I've seen the code, and yes, it is safe."
FROM http://forum.hosts-file.net/vi...
(On my latest 9.0++ code engine above & from past versions -> http://slashdot.org/comments.p... )
A competent coder & BEST security researcher I know of FROM THE BEST ANTIMALWARE THERE IS http://www.av-test.org/en/news...
NOT a secretary!
I don't give away work to be stolen OR misused like GOOGLE CHROME http://it.slashdot.org/story/1...
---
"won't demonstrate security of his product be exposing the source" - by Coren22 (1625475) on Wednesday November 18, 2015
Bullshit: 62 reputable sources + /. users say different:
Safe by 57 antivirus programs in 64-bit model https://www.virustotal.com/en/...
+
the 32-bit model https://www.virustotal.com/en/...
&
Per VirScan (installer too)-> http://f.virscan.org/APKHostsF...
MalwareBytes' hpHosts Admin (MalwareBytes employee) hosts & recommends it -> http://hosts-file.net/?s=Downl... & MalwareBytes = BEST antivirus per this VERY recent testing of them all http://www.av-test.org/en/news...
APK
P.S.=> Eat your words, scumbag:
Tell us about AD + DNS too while you're @ it & how you said I said not to run DNS when I use it myself & said to NOT use external to network DNS with AD http://slashdot.org/comments.p...
OR
About how my program NEEDS admin privelege to update too (& it doesn't http://slashdot.org/comments.p... )
LOL... fool - 'eat your words' on ALL those accounts chump!
... apk
"the secretary at MalwareBytes took a look at his source code and said it looked all good to them" - by Coren22 (1625475) on Wednesday November 18, 2015
My code went thru verification by Mr. Steven Burn of Malwarebytes' hpHosts
hpHosts Site Admin Mr. Steven Burn quoted:
"I've been asked to further clarify so for the record yes I've seen the code, and yes, it is safe."
FROM http://forum.hosts-file.net/vi...
(On my latest 9.0++ code engine above & from past versions -> http://slashdot.org/comments.p... )
A competent coder & BEST security researcher I know of FROM THE BEST ANTIMALWARE THERE IS http://www.av-test.org/en/news...
NOT a secretary!
I don't give away work to be stolen OR misused like GOOGLE CHROME http://it.slashdot.org/story/1...
---
"won't demonstrate security of his product be exposing the source" - by Coren22 (1625475) on Wednesday November 18, 2015
Bullshit: 62 reputable sources + /. users say different:
Safe by 57 antivirus programs in 64-bit model https://www.virustotal.com/en/...
+
the 32-bit model https://www.virustotal.com/en/...
&
Per VirScan (installer too)-> http://f.virscan.org/APKHostsF...
MalwareBytes' hpHosts Admin (MalwareBytes employee) hosts & recommends it -> http://hosts-file.net/?s=Downl... & MalwareBytes = BEST antivirus per this VERY recent testing of them all http://www.av-test.org/en/news...
APK
P.S.=> Eat your words, scumbag:
Tell us about AD + DNS too while you're @ it & how you said I said not to run DNS when I use it myself & said to NOT use external to network DNS with AD http://slashdot.org/comments.p...
OR
About how my program NEEDS admin privelege to update too (& it doesn't http://slashdot.org/comments.p... )
LOL... fool - 'eat your words' on ALL those accounts chump!
... apk
"the secretary at MalwareBytes took a look at his source code and said it looked all good to them" - by Coren22 (1625475) on Wednesday November 18, 2015
My code went thru verification by Mr. Steven Burn of Malwarebytes' hpHosts
hpHosts Site Admin Mr. Steven Burn quoted:
"I've been asked to further clarify so for the record yes I've seen the code, and yes, it is safe."
FROM http://forum.hosts-file.net/vi...
(On my latest 9.0++ code engine above & from past versions -> http://slashdot.org/comments.p... )
A competent coder & BEST security researcher I know of FROM THE BEST ANTIMALWARE THERE IS http://www.av-test.org/en/news...
NOT a secretary!
I don't give away work to be stolen OR misused like GOOGLE CHROME http://it.slashdot.org/story/1...
---
"won't demonstrate security of his product be exposing the source" - by Coren22 (1625475) on Wednesday November 18, 2015
Bullshit: 62 reputable sources + /. users say different:
Safe by 57 antivirus programs in 64-bit model https://www.virustotal.com/en/...
+
the 32-bit model https://www.virustotal.com/en/...
&
Per VirScan (installer too)-> http://f.virscan.org/APKHostsF...
MalwareBytes' hpHosts Admin (MalwareBytes employee) hosts & recommends it -> http://hosts-file.net/?s=Downl... & MalwareBytes = BEST antivirus per this VERY recent testing of them all http://www.av-test.org/en/news...
APK
P.S.=> Eat your words, scumbag:
Tell us about AD + DNS too while you're @ it & how you said I said not to run DNS when I use it myself & said to NOT use external to network DNS with AD http://slashdot.org/comments.p...
OR
About how my program NEEDS admin privelege to update too (& it doesn't http://slashdot.org/comments.p... )
LOL... fool - 'eat your words' on ALL those accounts chump!
... apk
"the secretary at MalwareBytes took a look at his source code and said it looked all good to them" - by Coren22 (1625475) on Wednesday November 18, 2015
My code went thru verification by Mr. Steven Burn of Malwarebytes' hpHosts
hpHosts Site Admin Mr. Steven Burn quoted:
"I've been asked to further clarify so for the record yes I've seen the code, and yes, it is safe."
FROM http://forum.hosts-file.net/vi...
(On my latest 9.0++ code engine above & from past versions -> http://slashdot.org/comments.p... )
A competent coder & BEST security researcher I know of FROM THE BEST ANTIMALWARE THERE IS http://www.av-test.org/en/news...
NOT a secretary!
I don't give away work to be stolen OR misused like GOOGLE CHROME http://it.slashdot.org/story/1...
---
"won't demonstrate security of his product be exposing the source" - by Coren22 (1625475) on Wednesday November 18, 2015
Bullshit: 62 reputable sources + /. users say different:
Safe by 57 antivirus programs in 64-bit model https://www.virustotal.com/en/...
+
the 32-bit model https://www.virustotal.com/en/...
&
Per VirScan (installer too)-> http://f.virscan.org/APKHostsF...
MalwareBytes' hpHosts Admin (MalwareBytes employee) hosts & recommends it -> http://hosts-file.net/?s=Downl... & MalwareBytes = BEST antivirus per this VERY recent testing of them all http://www.av-test.org/en/news...
APK
P.S.=> Eat your words, scumbag:
Tell us about AD + DNS too while you're @ it & how you said I said not to run DNS when I use it myself & said to NOT use external to network DNS with AD http://slashdot.org/comments.p...
OR
About how my program NEEDS admin privelege to update too (& it doesn't http://slashdot.org/comments.p... )
LOL... fool - 'eat your words' on ALL those accounts chump!
... apk
"the secretary at MalwareBytes took a look at his source code and said it looked all good to them" - by Coren22 (1625475) on Wednesday November 18, 2015
See subject: After you had to eat them, lol: My code went thru verification by Mr. Steven Burn of Malwarebytes' hpHosts
hpHosts Site Admin Mr. Steven Burn quoted:
"I've been asked to further clarify so for the record yes I've seen the code, and yes, it is safe."
FROM http://forum.hosts-file.net/vi...
(On my latest 9.0++ code engine above & from past versions -> http://slashdot.org/comments.p... )
A competent coder & BEST security researcher I know of FROM THE BEST ANTIMALWARE THERE IS http://www.av-test.org/en/news...
NOT a secretary!
I don't give away work to be stolen OR misused like GOOGLE CHROME http://it.slashdot.org/story/1...
---
"won't demonstrate security of his product be exposing the source" - by Coren22 (1625475) on Wednesday November 18, 2015
Bullshit: 62 reputable sources + /. users say different:
Safe by 57 antivirus programs in 64-bit model https://www.virustotal.com/en/...
+
the 32-bit model https://www.virustotal.com/en/...
&
Per VirScan (installer too)-> http://f.virscan.org/APKHostsF...
MalwareBytes' hpHosts Admin (MalwareBytes employee) hosts & recommends it -> http://hosts-file.net/?s=Downl... & MalwareBytes = BEST antivirus per this VERY recent testing of them all http://www.av-test.org/en/news...
APK
P.S.=> Eat your words, scumbag:
Tell us about AD + DNS too while you're @ it & how you said I said not to run DNS when I use it myself & said to NOT use external to network DNS with AD http://slashdot.org/comments.p...
OR
About how my program NEEDS admin privelege to update too (& it doesn't http://slashdot.org/comments.p... )
LOL... fool - 'eat your words' on ALL those accounts chump!
... apk
No! No! No! Pfizer just wanted to be based in the country that ranked #1 on the Good Country list! Which just happens to be Ireland, If you were Pfizer wouldn't you? http://www.goodcountry.org/
great to see jobs being created in Ãire :)
The U.S. Expatriation Tax is not a hardship by any reasonable definition of hardship...
It's not a question of "hardship". Stealing from people is wrong. Even when the victim has some money left over afterward.
Only tax cowards think the government is simply stealing from you. All your wealth you created in the USA was done because the USA has roads, public infrastructure and police, hospitals, and the *rule of law* to prevent others from stealing your wealth, or just stabbing you in your sleep for their own pleasure.
In short, your wealth was not created in a vacuum and it costs money to keep this infrastructure in place. You may bicker with the details or even a major part of how that tax is collected and spent (I sure do), but to claim it's stealing is to show ignorance of why it exists.
Or do you really think you'd have been better of born in Sierra Leone where there aren't such pesky taxes?
Make sure everyone's vote counts: Verified Voting
"the secretary at MalwareBytes took a look at his source code and said it looked all good to them" - by Coren22 (1625475) on Wednesday November 18, 2015
My code went thru verification by Mr. Steven Burn of Malwarebytes' hpHosts
hpHosts Site Admin Mr. Steven Burn quoted:
"I've been asked to further clarify so for the record yes I've seen the code, and yes, it is safe."
FROM http://forum.hosts-file.net/vi...
(On my latest 9.0++ code engine above & from past versions -> http://slashdot.org/comments.p... )
A competent coder & BEST security researcher I know of FROM THE BEST ANTIMALWARE THERE IS http://www.av-test.org/en/news...
NOT a secretary!
I don't give away work to be stolen OR misused like GOOGLE CHROME http://it.slashdot.org/story/1...
---
"won't demonstrate security of his product be exposing the source" - by Coren22 (1625475) on Wednesday November 18, 2015
Bullshit: 62 reputable sources + /. users say different:
Safe by 57 antivirus programs in 64-bit model https://www.virustotal.com/en/...
+
the 32-bit model https://www.virustotal.com/en/...
&
Per VirScan (installer too)-> http://f.virscan.org/APKHostsF...
MalwareBytes' hpHosts Admin (MalwareBytes employee) hosts & recommends it -> http://hosts-file.net/?s=Downl... & MalwareBytes = BEST antivirus per this VERY recent testing of them all http://www.av-test.org/en/news...
APK
P.S.=> Eat your words, scumbag:
Tell us about AD + DNS too while you're @ it & how you said I said not to run DNS when I use it myself & said to NOT use external to network DNS with AD http://slashdot.org/comments.p...
OR
About how my program NEEDS admin privelege to update too (& it doesn't http://slashdot.org/comments.p... )
LOL... fool - 'eat your words' on ALL those accounts chump!
... apk
I'm gonna post this as AC again. It's probably obvious, to some, who I am but that's okay. Allow me my faux anonymity!
You've never actually expatriated money, have you? I can assure you that, with a decent attorney and accountant, you're not going to pay anywhere near that amount. It's more like 20% as I recall but I don't have the figures with me here in the hotel room. (And yes, you can expatriate wealth - it's actually a good idea to do some as a means of diversifying and protecting your interests. It's not just for people.)
The idea that it is 40% is laughable. In a previous comment you indicated that $2M USD was a fortune. That too is laughable. It only seems like a large sum because you've obviously never spent that much. My business spent that much on hardware (Sun is a very costly) for example.
Oddly, you seem to think that taxes are too high for those who have accumulated some wealth. I do not understand this. I appreciate your concern, I really do, but when you reach a certain level of wealth and hire qualified people, you don't actually pay anywhere near what you seem to think you pay. Even if you did, it's really not that much of a burden. If some wealthy person is telling you that they're concerned that their current taxation is too high, they're trying to manipulate you into speaking on their behalf - don't do that.
Seriously, a lot of this stuff is a matter of public record. If you knew my full name and, I think, social security number and address (you could Google some of this) you'd actually be able to view my tax records. They're public information - no FOIA paperwork needed or the likes. I pay every last dollar owed and avoid quite a bit of taxation (evasion is illegal, avoidance is an ethical requirement). I don't know what you think I pay in taxes but I can tell you, it's a damned shame.
I'd probably stop working so hard (and paying so much) to avoid taxes but, honestly, how you guys spend it is kind of pissing me off. I really don't like paying for you to bomb brown people, jail people guilty of victimless crimes, or waste money on security theater. If you spent it fixing infrastructure, feeding the poor, or healing the sick then I might not only stop avoiding taxes and reducing my tax burden but I might actually pay extra. Heh... Imagine that.
Anyhow, you expatriate the money and then you invest it in foreign markets. At that point you don't even get taxed on it until you move it from the markets and spend it. When you do spend some of it then you're taxed, as/if applicable, at the capital gains rates which vary a little but the most I think I've ever paid would be in the 15% range. What you see as a total tax rate is marginal tax rate and I don't do any short term investments so I can't speak to those. My tax rate is the marginal tax rate for capital gains and I don't spend a whole lot, I guess, comparatively speaking. I think that it actually maxes out at about 20%.
Another thing to consider is that, with few exceptions, money is charged taxes every time it moves. This is how it has been for a long time and is how it is going to be in the future. When the business gets taxed and then I, as a stock holder, am taxed it's not really double taxation - it's me paying my obligated dues on an income that I have earned by virtue of allowing others to use my wealth to keep their business flowing, grow their business, or start their business. I'm taxed on my income as the business is taxed on its earnings.
There's no double taxation going on here. I own shares in the company but I am not the company. Just like the company pays taxes and pays you and you pay taxes on your income, that's just the way it works and, I guess, rightfully so. Of course we can argue as to where the lines need to be drawn but we pretty much have to have taxes. Utopian ideals are nice but hardly practical.
100%
Without US rules and laws, all of Apples patents would be worthless and anyone could make a copy of an iWhatever and sell it cheap.
100% Without US rules and laws, all of Apples patents would be worthless and anyone could make a copy of an iWhatever and sell it cheap.
Apple would make no money at all.
Tax Corporate Revenues, Not Profits;
http://news.yahoo.com/warren-b...
Casteism
"Everyone who does use HOSTS files (myself included) doesn't use your software" - by dave420 (699308) on Thursday November 05, 2015 @07:30AM (#50869743)
Some /.'ers made you "eat your words": They use my hosts file engine saying it's good vs. your bullshit:
"his hosts program is actually pretty good" - by xenotransplant (4179011) on Monday August 10, 2015 @03:34PM (#50287195)
"I like your host file system." - by Karmashock (2415832) on Wednesday September 09, 2015 @03:57PM (#50489401)
"APK is kinda right... I've given up on JS based adblocking and gone to blackholing in /etc/hosts, just like it was back in the 90s. The computational load has gotten intolerable for any ad-blocking using JS. I've tried his hosts file generating software. It works." - by bmo (77928) on Thursday October 15, 2015 @11:30AM (#50736071)
"his hosts tool is actually useful for those cases in which one does indeed want to locally block stuff outright while consuming minimum system resources" by alexgieg (948359) on Friday September 25, 2015 @09:57AM (#50596461)
(LMAO... you FAIL as usual, again, vs. me!)
* What's that you said I have quoted from you above Dave420?
APK
P.S.=> Thanks for making me look good: You always say something I can put away with undeniable facts that prove you wrong... lol!
... apk
"You have no supporters with accounts" - by dave420 (699308) on Monday November 23, 2015 @11:17AM (#50985793)
See subject & a quote of your words you must eat vs. me again:
Tepples does http://slashdot.org/comments.p...
aaaaaaargh! does http://yro.slashdot.org/commen...
Trax3001BBS does http://news.slashdot.org/comme...
KGIII does http://yro.slashdot.org/commen...
* So do all these /.'ers:
"No complaints from me, I like APK's spam. Reminds me to use a host file. Also, his stuff is free." - by aaaaaaargh! (1150173) on Tuesday November 17, 2015
"his hosts program is actually pretty good" - by xenotransplant (4179011) on Monday August 10, 2015
"I like your host file system." - by Karmashock (2415832) on Wednesday September 09, 2015
"APK is kinda right... I've given up on JS based adblocking and gone to blackholing in /etc/hosts, just like it was back in the 90s. The computational load has gotten intolerable for any ad-blocking using JS. I've tried his hosts file generating software. It works." - by bmo (77928) on Thursday October 15, 2015
"Actually, APK is totally right on this count. Adblock Plus on Firefox mobile is a dog on older, or lower end, phones. A hostfile based adblocker makes for a much better experience in this context. Of course, your phone has to be rooted, which isn't the case with Firefox + adblock." - by chihowa (366380) on Saturday May 16, 2015
"his hosts tool is actually useful for those cases in which one does indeed want to locally block stuff outright while consuming minimum system resources" by alexgieg (948359) on Friday September 25, 2015
"APK isn't wrong" - by cfalcon (779563) on Sunday October 04, 2015
"In a footnote, I would like to note that I find your hosts file admirable." - by vel-ex-tech (4337079) on Tuesday November 24, 2015
APK
P.S.=> What's that you said Dave420? Outnumbered by 12++:1 for starters?? LMAO... apk
Hmmm... now, I wonder if this is the fault of Pfizer or the fault of onerous taxation?