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Apple May Bring Back Billions In Profits To The U.S. (siliconbeat.com)

An anonymous Slashdot reader quotes a report from the San Jose Mercury News: Apple CEO Tim Cook says the company plans to bring back billions of dollars in profit to the U.S. next year. Cook's statement, made during an interview with RTE radio Thursday, contradicts his previous public statements on the issue: He has said for years that U.S. corporate taxes are too high, and that the Silicon Valley company wouldn't be repatriating profit until its home country changed its tax code.

"Right now I would forecast that we repatriate next year"Cook said, saying that the company has "provisioned several billion" for that purpose.

An interesting side-note: Apple accounts for 40% of Silicon Valley's profits.

302 comments

  1. Empty threat by Anonymous Coward · · Score: 5, Insightful

    Apple just wants to scare the EU, there are plenty of other countries they will hold their money that won't charge as much as the US will.

    1. Re:Empty threat by Anonymous Coward · · Score: 0

      Apple just wants to scare the EU, there are plenty of other countries they will hold their money that won't charge as much as the US will.

      Apple doesn't want to scare shit. They know full well they can buy Congress and the Senate no questions asked.
      So it's more profitable for them to repatriate some of those funds to the US than have them lost to the European taxman.

    2. Re:Empty threat by Anonymous Coward · · Score: 2, Interesting

      Apple is "repatriating" their money before the US Congress does away with the deferred tax payment provisions in the tax code. The code basically allows any company to book profits in other countries and basically agrees to paying the deferred taxes if they repatriate their money. Both the US government and the big US corporations are sensitive to bad press. The government could "request" the large corporations repatriate their money and equate that request with US patriotism. One can only hope all the other US companies doing business in Europe does the same thing. It will be cheaper to pay US taxes than worry about the EU\EC passing retroactive tax laws and other fines or penalties. Ireland attracts companies because of their favorable tax rates. That was not a secret and did not violate any EU laws. They have been doing this for awhile with no complaints. Did the EU just not notice? They have gobs of useless officials in Brussels that are supposed to be monitoring these types of things.

      Since Europe has not produced any technology firms to compete with US tech companies they are left with shaking down profitable US companies. It's amazing the morons in EU\EC think they can harass US companies and not evoke a response from the US.

    3. Re:Empty threat by Anonymous Coward · · Score: 5, Insightful

      Ireland attracts companies because of their favorable tax rates.

      Calling 0.005% tax on global profits (yes, really, not a typo) favorable tax rates is at least an euphemism

      did not violate any EU laws.

      They argue it that does violate preexisting EU conditions and that is indeed ilegal.

      It's amazing the morons in EU\EC think they can harass US companies and not evoke a response from the US.

      Roger. We get it.

    4. Re: Empty threat by Anonymous Coward · · Score: 0

      Quit calling him Roger. Her name is surely.

    5. Re:Empty threat by jopsen · · Score: 5, Insightful

      It's amazing the morons in EU\EC think they can harass US companies and not evoke a response from the US.

      Oh, cry me a river... There are courts in the EU, you are more likely to see your rights honor there than in the US, a country known to deny effective council, torture people and lock up people without trial.

      When you workaround taxes in both the EU and US, I for one encourage Vestager to throw the book at you. Really, when a company like Apple decides to test boundaries of the law, Apple should expect the authorities to do exactly the same.

      On topic, I'm sure the US generally likes this because without this pressure the money would have stayed in tax shelters. I for one think it's okay to go after companies that are actively speculating against the state, in hope of better future tax breaks...

    6. Re:Empty threat by Archfeld · · Score: 2

      From what I read the UE is not threatening to levy penalties, but is saying you should have collect X, if you choose to take less so be it, but we are going to base subsidies on what you should have collected, not on what you choose to collect, so if you want to let money walk away go for it, but don't expect us to provide anything to bridge the gap. I could of course be mistaken I am neither a lawyer nor an accountant, and I certainly am not a soothsayer able to see the mysterious future.

      --
      errr....umm...*whooosh* *whoosh* Is this thing on ?
    7. Re: Empty threat by Anonymous Coward · · Score: 0

      Yeah, the Europeans are a bastion of fairness and morality. Nevermind the gold bricks that still sit in German reserves that were once inside teeth pulled from ovens.

    8. Re: Empty threat by Anonymous Coward · · Score: 2, Insightful

      Yawn. Similar point about Native American genocide and slavery.

      Your turn.

    9. Re:Empty threat by FlyHelicopters · · Score: 0, Flamebait

      Roger. We get it.

      No, you don't...

      You want expensive? How about we withdraw from NATO and let Germany worry about Russia on their own?

      You don't suppose the require defense spending increase will be expensive, do you?

      It may seem the US and EU have each other over a barrel, but it just SEEMS that way...

    10. Re: Empty threat by Hevel-Varik · · Score: 1

      1940.

    11. Re:Empty threat by Anonymous Coward · · Score: 0

      capital oh capital you know no country!

    12. Re:Empty threat by ultranova · · Score: 1

      How about we withdraw from NATO and let Germany worry about Russia on their own?

      That will end up with the return of either the Nazis - this time with nukes - or the Soviet Union or, in the absolute best case, EU turning into a real federation which will be the new #1 superpower on the planet.

      --

      Forget magic. Any technology distinguishable from divine power is insufficiently advanced.

    13. Re:Empty threat by guises · · Score: 1

      They have been doing this for awhile with no complaints.

      No complaints? There has been non-stop complaining about this from the rest of the EU. Some kind of reprisal has been coming for quite a while, the fact that they've moved slowly on it does not mean that Ireland's tax policy was an accepted practice.

    14. Re:Empty threat by FlyHelicopters · · Score: 0, Flamebait

      That will end up with the return of either the Nazis

      Ha! Nice try... "better pay up and guard us or the boogie man will come back"

      Try again...

    15. Re:Empty threat by ultranova · · Score: 3, Insightful

      Since Europe has not produced any technology firms to compete with US tech companies they are left with shaking down profitable US companies. It's amazing the morons in EU\EC think they can harass US companies and not evoke a response from the US.

      And what response would be appropriate for the EU shutting down a tax haven a US company was using to avoid US taxes? A "thank you" note?

      Not that Apple is really a US company. It's an international company with zero loyalty to anyone. It deserves none in return.

      --

      Forget magic. Any technology distinguishable from divine power is insufficiently advanced.

    16. Re:Empty threat by smallfries · · Score: 1

      Yup, the EU is terrified that Apple may avoid paying taxes in America rather than evade paying taxes in Europe. All that lost money!

      --
      Slashdot: where don knuth is an idiot because he cant grasp the awesome power of php
    17. Re:Empty threat by Zontar+The+Mindless · · Score: 1, Funny

      Feel that tapping on your shoulder? That's Neville Chamberlain. He'd like to talk to you...

      --
      Il n'y a pas de Planet B.
    18. Re: Empty threat by Zontar+The+Mindless · · Score: 1

      Trail of Tears.

      --
      Il n'y a pas de Planet B.
    19. Re:Empty threat by Gussington · · Score: 2

      No, you don't...

      You want expensive? How about we withdraw from NATO and let Germany worry about Russia on their own?

      So if you withdraw from NATO, Putin will just leave the US alone? That's a new kind of naive I haven't seen around here for a while...

    20. Re:Empty threat by Anonymous Coward · · Score: 1

      I don't really see the problem here, and anyone saying it's EU vs US is probably just being a xenophobic prick.

      Really, this is win-win for everyone, because it puts tax havens into place, and it helps stop corporations dictating how the US is run rather than, you know, the people, because it means they can no longer make billions in profits and use those billions as a lobbying tool against the US government to try and exercise undue influence in politics.

      This seems like an excellent outcome, as the EU can now more easily police tax havens and companies that aren't playing by the rules, and the US is more likely to also get it's cut too. This is way better than money lingering for decades outside of the productive economy.

      Had all these large companies (and I don't mean just tech companies, and I don't mean just US companies) been paying the tax they're supposed to pay over the years I doubt for one moment the financial crisis would've been so bad. The money owed to Ireland would've been enough for it's public finances to be balanced such that it wouldn't have needed a bailout and would never have been at risk of bankruptcy.

      These actions in making Apple pay it's share of tax are a carry on from that, ever since 2008 governments have realised they can't just turn a blind eye to wide scale tax evasion and avoidance because it has a real actual cost, because money being used in this way isn't anywhere near as productive as money flowing through the economy as salaries, purchases and so on and so forth.

      This is good news for everyone and anyone bitching about it is likely either a xenophobic cock or just plain economically illiterate.

    21. Re:Empty threat by Maxo-Texas · · Score: 3, Informative

      The european commission ruled the 0.005% tax rate was illegal because Ireland only gave it to Apple. They did not give it to other businesses. So it was unfair subsidy to a single business and anticompetitive.

      I imagine that the 14.5 billion dollar tax bill is a part of why Tim Cook is getting the money out now. Not all of it, but part of it.

      Governments are getting wise to the internet and shutting down these abusive situations where companies book profits or pay 100% of profits as franchise fees to other countries. Companies are cracking down on this and probably in 5-10 years if you sell $10 of product or services in a company, you will pay taxes on $10 dollars worth of gross sales.

      --
      She was like chocolate when she drank... semi-sweet at first and then increasingly bitter.
    22. Re:Empty threat by EvilAlphonso · · Score: 5, Insightful

      Ireland attracts companies because of their favorable tax rates. That was not a secret and did not violate any EU laws.

      Ireland's corporate tax rate is 12.5%, the second lowest in the world. The EU doesn't have any issue with that rate. What Apple negotiated was an effective 0.005% tax rate instead of the 12.5% rate. Notice that the number is different. What the EU is asking is that Apple pays the 12.5% tax rate as the 0.005% tax rate has been ruled a state subsidy. State subsidies were made illegal inside the EEC (now EU) by the treaty of Rome in 1958. So yes, it does violate a EU law... one of the founding laws of the EU common market.

      It will be cheaper to pay US taxes than worry about the EU\EC passing retroactive tax laws and other fines or penalties.

      Because it is well known that paying 35% is cheaper than paying 12.5%, which is the tax rate Apple is being asked to pay. Ireland is bound by the treaty of Rome since they joined the EEC in 1973. Apple opened its Irish operations in Ireland after Ireland became a member of the EEC. This has nothing to do with retroactive tax laws, the deal Apple received from the Irish tax authority was illegal from day 1.

      The EU is also only asking for the last 10 years of due taxes, instead of all taxes due since the beginning of Apple operations in Ireland.

      If Apple doesn't want to pay its taxes in the EU, it is more than welcome to take its ball and GTFO. If Ireland doesn't want to play along with the rules of the EU market, they can also pay back the money they still owe the EU early and GTFO. They have effectively sold the rest of the EU market down the river. I'm sure international companies will still flock to their shores once Ireland is no longer a member of the EU market and the companies can no longer passport activities/taxes from there.

      By the way, it is cute that you believe Apple will pay more taxes in the US. According to a senate inquiry in 2013, Apple is using a subsidiary that effectively pays no tax whatsoever in any jurisdiction to shelter a good quarter of its assets. According to the same senate inquiry in 2013, Apple has been funneling money to the Irish operations in order to avoid paying $11bn in taxes a year between 2009 and 2013. Apple is also apparently misreporting to its shareholder the amount of taxes it pays in the US... what they tell their investors is twice the amount that the IRS can account for.

      It's amazing the morons in EU\EC think they can harass US companies and not evoke a response from the US.

      It's amazing that the morons in global companies think that they are not bound to the laws of the places where they operate. It's equally funny that you still consider Apple an US company when it's currently not producing in the US, has more than twice the assets outside the US than it has in it and its best innovations lately are in the field of tax avoidance. Also, out of curiosity, can you name the last two companies with record fines from the EU for the same type of deal?

    23. Re: Empty threat by Anonymous Coward · · Score: 0

      We're talking about US companies hiding profits from tax, not NATO.

      Anyway screw NATO, they're a bunch of big boys playing games with expensive toys. How did they help Ukraine (or anyone, ever)?

    24. Re: Empty threat by Anonymous Coward · · Score: 0

      Phew, thanks European Commission, you saved us all.

    25. Re: Empty threat by ravenshrike · · Score: 1

      The problem with the Trail of Tears is it only happened after the Cherokee president illegally maintained power and several of the opposing political faction in the Cherokee Nation who saw the writing on the wall and wanted to get out of dodge were assassinated. There was no way in hell that the US would have allowed a prosperous Indian nation with large amounts of gold to exist inside its own borders for any real length of time. Had they left while Jackson was in office, they would have had more money, and all their movable possessions. Instead Ross played chicken with the US Govt. and lost badly.

    26. Re:Empty threat by Anonymous Coward · · Score: 0

      > Oh, cry me a river... There are courts in the EU, you are more likely to see your rights honor there than in the US, a country known to deny effective council, torture people and lock up people without trial.

      And executing people. Don't forget executing people.

      Literally killing its own citizens (reprehensible, or frequently innocent, as they might be).

    27. Re:Empty threat by LifesABeach · · Score: 1

      ..."It's amazing the morons in EU\EC think they can harass US companies and not evoke a response from the US..."

      Hay thanks EU, great idea. American companies have for to long enjoyed their locus rampaging ways; while not giving back to the community; think John Nash's works. And the world has suffered for it. Maybe this is the turning point?

    28. Re:Empty threat by TFAFalcon · · Score: 2

      What do you mean US companies? Apple Ireland is an European company.

    29. Re: Empty threat by Anonymous Coward · · Score: 2, Insightful

      You want expensive? How about we withdraw from NATO and let Germany worry about Russia on their own?

      Is that a threat or a promise?
      PLEASE, get the fuck out of our country already. I'd feel way more safe that way.
      And stop pretending that Russia is starting more wars than you do.

    30. Re:Empty threat by bytesex · · Score: 5, Informative

      Exactly. The EU's beef is primarily with Ireland, only secondarily with Apple. The thing is: Ireland is a net receiver of EU money. So the EU reasons: if you want subsidies, you have a certain obligation to pick up certain types of money, taxes being one of them. Otherwise it would create a perverse incentive to EU nations: don't collect taxes, let the rest of the EU countries pick up the bill. So the EU demands, in exchange for membership, a tax regime of a certain quality. Since they are the ones paying, they decide. Germany, for example, could decide not to tax Apple a penny, but it wouldn't get a similar frown from the EU, since it's a net payer into the system.

      So the EU says to Ireland: collect, or we'll lower your subsidy by an equal amount. And Ireland finds itself caught between a rock and a hard place.

      --
      Religion is what happens when nature strikes and groupthink goes wrong.
    31. Re:Empty threat by Anonymous Coward · · Score: 0

      Companies are cracking down on this and probably in 5-10 years if you sell $10 of product or services in a company, you will pay taxes on $10 dollars worth of gross sales.

      Sounds like either a sales tax or a turnover tax. Ireland had a turnover tax once (and I remember it), but it was replaced by VAT.

    32. Re:Empty threat by swillden · · Score: 2

      Really, when a company like Apple decides to test boundaries of the law

      By "test the boundaries of the law" you actually mean "comply with a 25 year-old agreement with a sovereign nation that still argues that the agreement is wholly correct and is considering suing the EU for attempting to invalidate it".

      Apple should expect the authorities to do exactly the same.

      And by "do exactly the same" you mean "move the boundaries".

      http://www.economist.com/news/leaders/21706267-european-commissions-assault-technology-giant-wrong-bruised-apple

      --
      Note to ACs: I usually delete AC replies without reading them. If you want to talk to me, log in.
    33. Re:Empty threat by robsku · · Score: 1

      Roger. We get it.

      No, you don't...

      You want expensive? How about we withdraw from NATO and let Germany worry about Russia on their own?

      I'm sure that people are now crying in fear, locking themselves in their homes or rioting - or both at once. They are so desperate because *you* threatened them with NATO leaving them alone.

      PS. If there was any way you could cause that to happen, I for one would gladly chip in to get you take NATO away from the whole Europe. It's part of the problem, not the solution, and currently it's trying to convince more countries in Europe to join, like Finland where I live and where we want to have nothing to do with NATO. Your grasp of realities of global politics isn't that great.

      --
      In capitalist USA corporations control the government.
    34. Re:Empty threat by robsku · · Score: 1

      When you workaround taxes in both the EU and US, I for one encourage Vestager to throw the book at you. Really, when a company like Apple decides to test boundaries of the law, Apple should expect the authorities to do exactly the same.

      Word. And in fact to pretend that Apple didn't really know about EU tax rules and Cook is honest (LOL, https://www.fastcompany.com/30... ), is basically equivalent of saying that "Apple isn't crooked, they are just *incredibly* stupid - and so am I" :P

      On topic, I'm sure the US generally likes this because without this pressure the money would have stayed in tax shelters. I for one think it's okay to go after companies that are actively speculating against the state, in hope of better future tax breaks...

      Yup.

      --
      In capitalist USA corporations control the government.
    35. Re:Empty threat by Anonymous Coward · · Score: 0

      State subsidies were made illegal inside the EEC (now EU) by the treaty of Rome in 1958. So yes, it does violate a EU law... one of the founding laws of the EU common market.

      That's incorrect. State subsidies are only illegal if certain exceptions do not apply.

      "Paragraph 3 of Article 107, for its part, stipulates that the following may be considered to be compatible with the common market: aid to promote the economic development of areas with economic or social problems; aid to promote the execution of an important project of common European interest or to remedy a serious disturbance in the economy of a Member State; aid to facilitate the development of certain economic activities or of certain economic areas, where such aid does not adversely affect trading conditions; aid to promote culture and heritage conservation; and such other categories of aid as may be specified by decision of the Council"

      Every single one of those exceptions applied to the case of Ireland in the immediate post-Cold War era, when the Irish tax laws were set up to encourage economic development. Ireland was not only an economic disaster - almost a third world country - but also an acute embarrassment to the EU at a time when they desperately wanted to look good in the eyes of the recently-freed states of Eastern Europe. The Irish policies were quite sensible: it's always better to pull oneself out of a hole then to become a welfare state, dependent on the central government for handouts (though there are some in politics that prefer the latter state of affairs). In all likelihood, the EU encouraged Ireland to adopt the policies that it did, with the expectation that any problems could be corrected down the road.

      At one point, the rules barred recovery of State Aid already granted (which of course implies no prior permission is needed to grant the State Aid):

      "Where the decision is on existing aid, the Commission cannot order the recovery of aid already given, but will prevent the Member State from granting future aid."

      However, the rules have changed multiple times during the past few decades and I don't know which version is applicable now. The EU's web sites are currently inconsistent and contradictory, which as a matter of ethical practice of law should invalidate the law and any actions taken under it. I suspect the EU government will be frantically trying to update their web sites.

    36. Re: Empty threat by Anonymous Coward · · Score: 0

      of course ireland is complaining. they are being accused of wrong doing by giving apple practically zero tax rate while say ibm is paying one. ireland maybe got some apple offices located in the deal. it's unfair to other companies

    37. Re: Empty threat by Anonymous Coward · · Score: 0

      yeah, that totally make the racism of US elites right

    38. Re: Empty threat by Anonymous Coward · · Score: 0

      The only people in Germany worried about Russia are Americans.

    39. Re:Empty threat by GNious · · Score: 2

      Just checking - is it more than 25 years since Ireland willingly joined the EEC in 1973, and willingly agreed to abide by the rules for the common market?

    40. Re:Empty threat by Anonymous Coward · · Score: 0

      Em, why not, since Putin only started 'attacking' the US after they tried to march NATO right up to the fence of his metaphorical back yard? I genuinely do wonder how people as dumb as you seem to be manage to survive without adult supervision, a quick summary of recent history might help you understand; Soviet Union collapsed, threat disappeared, cold war ended, former Soviet states started being integrated into EU. Putin and Russia had no problem with this, then the US tries to push a hostile MILITARY alliance right up to Putin's back door, orchestrating a coup in Ukraine in the process and you expect Putin just to go, oh that's fine, do whatever you like ? How dumb are you exactly, Russia took the high road and didn't rise to the US provocations for many years but the Ukraine stunt was the final straw, so he finally took action to prevent you assholes from taking the piss. As a European I would like nothing more than for you assholes to fuck right off back to your own continent (you know the one you stole from the natives after the whole genocide thing) and while you're at it it would be much appreciated if you could stop propping up financially that cesspool of criminal, racist, anti-semitic bums that calls itself 'Israel'.

    41. Re: Empty threat by Anonymous Coward · · Score: 0

      So is the kind of naive new or not? Either it's new and you haven't seen it before or it's not new and you have seen it sometime in the past.

    42. Re:Empty threat by Anonymous Coward · · Score: 0

      I feel the need to add that even though Germany is a net payer into the system, they are bound by the same rule and must give all companies the same tax rate.

    43. Re:Empty threat by Anonymous Coward · · Score: 0

      Nobody's is going to attack the territorial US so long as we have three entirely distinct systems to turn their country into a glass surface with nukes.

      Nobody. These regional conflicts are a game for justification of political power and ever-increasing defense budgets, for which we were at "utterly destroy anyone" 60 years ago. Both sides still play the game pretending Mutual Assured Destruction isn't still the endgame, because both sides profit.

    44. Re:Empty threat by Anonymous Coward · · Score: 0

      True. There's nothing else to add.

    45. Re: Empty threat by Anonymous Coward · · Score: 0

      Dyslexia for cure found.

    46. Re:Empty threat by doccus · · Score: 1

      We "know* what all those officials are up to in Brussels. Thanks to the BBC and "Yes Minister" ;-)

    47. Re:Empty threat by FlyHelicopters · · Score: 0

      Feel that tapping on your shoulder? That's Neville Chamberlain. He'd like to talk to you...

      Again, nice try with the scare tactics...

      What you're REALLY saying is "the US better pay up and protect us or the boogie man will come back"

    48. Re: Empty threat by FlyHelicopters · · Score: 2

      Anyway screw NATO, they're a bunch of big boys playing games with expensive toys. How did they help Ukraine (or anyone, ever)?

      You might want to learn something before you open your mouth...

      Ukraine is not a member of NATO...

    49. Re: Empty threat by Anonymous Coward · · Score: 0

      Nobody will fly planes into buildings either.

    50. Re:Empty threat by Anonymous Coward · · Score: 0

      Yeah, but how many of those would you trust to hold that sort of money?

      The EU is, financially and politically speaking, reasonably stable - it's unlikely that your bank there is going to collapse without compensation, the currency is going to vanish down the toilet, or the government is going to announce that it's just keeping all your money to finance its own programmes, kthxbye.

      Not everyone has to close their loopholes - only those who seem sufficiently trustworthy. Apple would be insane to put that kind of money in, e.g., Brazil or Russia or India. I guess Australia, NZ, Japan, S Korea are still open, but they don't have particularly friendly tax regimes, and anyway they could decide at any moment to do what the EU just did.

    51. Re:Empty threat by Anonymous Coward · · Score: 0

      It's not so much the payments or subsidies made by the EU. It is the rules of membership. The EU is basically an agreement between countries. One of those rules in that agreement is that countries enjoying membership shall not tax snipe the other members. It doesn't matter if there is some perceived net positive or negative payment from the EU.

    52. Re:Empty threat by Big+Hairy+Ian · · Score: 1

      It's amazing the morons in EU\EC think they can harass US companies and not evoke a response from the US.

      Actually it's Ireland's illegal tax code they are after which should effect Google, Facepalm and all the rest too

      --

      Build a Man a Fire, and He'll Be Warm for a Day. Set a Man on Fire, and He'll Be Warm for the Rest of His Life.

    53. Re:Empty threat by Maxo-Texas · · Score: 1

      Refighting world war 2 against russia would be much more expensive than nato dues.

      Exiting nato and becoming isolationist again would lead to russias peaceful and non-peaceful expansion into europe.

      --
      She was like chocolate when she drank... semi-sweet at first and then increasingly bitter.
    54. Re:Empty threat by Anonymous Coward · · Score: 0

      it is perfectly fine that EU/Ireland/USA/whoever requires you to pay certain tax/fee/whatever, even if they increase/decrease it, but what i do not like is part where they asked corp to pay it retroactively.

      corporation made decision to move to Ireland because it was given guarantees by government tax rate will be 0%, if there was not such guarantee they would instead move to some other tax paradise

      at the time corp made that deal with Irish GOVERNMENT it was according to Irish law, if Irish law is not "correct" as part of EU law, Ireland is one that should pay any penalties for last 10/30 years and not apple, for apple they should just say "from now on since law changed, your tax rate will be xx% IF you want to stay in this country", you cant change laws and rules retroactively for corporations and people, even if they avoid laws, because that is first rule of law, it should be on your side if you follow it, even if you are in grey area of it

    55. Re:Empty threat by FlyHelicopters · · Score: 1

      Exiting nato and becoming isolationist again would lead to russias peaceful and non-peaceful expansion into europe.

      And the average American should care because?

      If Europe is unwilling to spend the money to defend itself, why should we?

    56. Re:Empty threat by Zontar+The+Mindless · · Score: 1

      No, what I'm really saying is that that those who ignore history are doomed to repeat it.

      And are difficult to take seriously as long as they persist in sticking their heads in the sand.

      --
      Il n'y a pas de Planet B.
    57. Re:Empty threat by ausekilis · · Score: 1

      All Apple is really doing is optimizing their overall bill. There's a balance to be made between the billions they owe in the EU versus repatriating some amount Xand paying the 35% on X. I'm no tax lawyer, but if they repatriate $10B, then they would owe ~$3.5B to the US, and presumably some smaller amount of the remaining taxes to the EU.

      I realize I'm completely off base with specifics (not a lawyer). Though I personally think there should be laws specific to the country that business was conducted in and taxes should be based specifically off of that. You do business in the US? Have an office, keep track of sales and profits made in the US. Ditto for EU, Japan, Russia, China, wherever. $65B kept on $100B profit in the US is still a lot of money, especially for a company like Apple that loves its cash reserves and doesn't go blow the wallet on R&D and acquisitions like Yahoo and MSFT.

    58. Re:Empty threat by FlyHelicopters · · Score: 1

      No, what I'm really saying is that that those who ignore history are doomed to repeat it.

      No, again, you're not...

      You're saying that Europe is unable to defend itself and if the US doesn't do it, then Europe is doomed...

      Well fuck em, if Europe can't take care of themselves and is not willing to pay for the required protection, then they don't deserve to remain as nations...

      France lost to Germany in 1940 because they were completely unprepared, they fought the last war, Germany fought the next one. They also didn't show up with a useful air force, tank divisions, or anti-tank guns.

      Germany won in 6 weeks because they came prepared.

    59. Re:Empty threat by Maxo-Texas · · Score: 1

      Because if europe were to come completely under russian sway we would lose most of our markets and russia would gain free access to the atlantic. in the end, it would probably result in the destruction of the u.s.

      The average U.S. citizen should care because it would could easily result in our exclusion from many markets and a catastrophic depression that lasted over a decade.

      --
      She was like chocolate when she drank... semi-sweet at first and then increasingly bitter.
    60. Re:Empty threat by FlyHelicopters · · Score: 1

      Because if europe were to come completely under russian sway we would lose most of our markets and russia would gain free access to the atlantic. in the end, it would probably result in the destruction of the u.s.

      Again, it comes back to "the US better pay up or the boogie man will come back"

      Fuck Europe, if they don't want to pay for their own defense, they don't deserve to remain free...

    61. Re:Empty threat by Maxo-Texas · · Score: 1

      You are rash and ignorant.

      Without Europe and russia as our allies in world war 2, we wouldn't have won.

      Without Europe (because we let them be conquered) we both make the next war more likely and more likely to be lost.

      --
      She was like chocolate when she drank... semi-sweet at first and then increasingly bitter.
  2. Go Apple! by Anonymous Coward · · Score: 1

    I'm sure being required to pay billions in Ireland even if they leave the money overseas, and the publicity that fighting that will have for their home tax arrangements, has nothing to do with this change of heart. Tim Cook is just a really nice guy who wants Apple to pay its fair share.

    (In before Google/Microsoft/whatever Apple competitor you think I MUST favor if I'm even mildly critical of Apple, are no doubt every bit as bad and worse and eat babies too).

  3. 40% of Silicon Valley's profits by Anonymous Coward · · Score: 1

    An interesting side-note: Apple accounts for 40% of Silicon Valley's profits.

    Another interesting side-note: Microsoft accounts for 95% of the software security problems of the planet.

    1. Re:40% of Silicon Valley's profits by __aaclcg7560 · · Score: 1

      Microsoft accounts for 95% of the software security problems of the planet.

      As an IT support contractor for 20+ years, I give thanks to Microsoft for providing daily job security.

    2. Re:40% of Silicon Valley's profits by Anonymous Coward · · Score: 0

      You obviously haven't met our friends at Adobe yet

    3. Re:40% of Silicon Valley's profits by Anonymous Coward · · Score: 1

      As much as MS may be a screw up. They put bread on the table. I have paid off a very nice house. Well over a half million saved and 2 BMWs. All thanks to papa MS.

      When I got out of college I thought I was going to change the world. I was going to be making next gen cutting edge stuff. I soon realized I was stringing together dialogs and forms to slug into some database for data no one will care about in 10 minutes. The amazing bit is people pay a *LOT* of money for this stuff.

    4. Re:40% of Silicon Valley's profits by Anonymous Coward · · Score: 0

      Most of this companies are using "legal" accounting tricks to manipulate profits for various tax and contract reasons.

    5. Re:40% of Silicon Valley's profits by wonkey_monkey · · Score: 2

      And 99% of AC cheap shots.

      --
      systemd is Roko's Basilisk.
    6. Re:40% of Silicon Valley's profits by Anonymous Coward · · Score: 0

      People who studied business had the same delusions about applying the theory they learned in college to make data driven decisions. The consequence is they fetishize metrics on the off-chance they will get an opportunity to apply Math above a HS Diploma level. Your job is to indulge those fantasies. Your feelings on the subject are pretty similar to those of a sex-worker or bar tender.

      https://www.youtube.com/watch?v=X7HmltUWXgs

    7. Re:40% of Silicon Valley's profits by Anonymous Coward · · Score: 1

      An interesting side-note: Apple accounts for 40% of Silicon Valley's profits.

      Another interesting side-note: Microsoft accounts for 95% of the software security problems of the planet.

      I think you will find that mantle actually belongs to Adobe followed closely by Mozilla with google/MS/apple/oracle a distant 3rd.

    8. Re:40% of Silicon Valley's profits by PopeRatzo · · Score: 1

      As an IT support contractor for 20+ years,

      Dude, you gotta look for something better, like, I don't know, being a professional poker player or HVAC or something. Sheet metal work pays good and you don't have to deal with Microsoft products.

      --
      You are welcome on my lawn.
    9. Re:40% of Silicon Valley's profits by __aaclcg7560 · · Score: 1

      Dude, you gotta look for something better, like, I don't know, being a professional poker player or HVAC or something. Sheet metal work pays good and you don't have to deal with Microsoft products.

      I'm making easy money as it is with Microsoft products. Meanwhile, I can focus on alternative streams of income that will eventually replace my IT job.

    10. Re:40% of Silicon Valley's profits by PopeRatzo · · Score: 2

      Thank you for your service.

      --
      You are welcome on my lawn.
    11. Re: 40% of Silicon Valley's profits by Anonymous Coward · · Score: 0

      I can't help it if my cayman Island company owns all my trademarks and takes 99% of my profits.

    12. Re:40% of Silicon Valley's profits by Anonymous Coward · · Score: 1

      I also though I was going to change the world and ended up stringing together dialogs and forms to slug into some database for data no one, including me, will care about in 10 minutes. The amazing bit is that it frustrated me a *LOT* that I became depressed and I could no longer do IT work.
       
      I'm currently a self employed construction worker. I string together bricks and stones and plaster to build a living place for people that those people will still care about within 20 years. The amazing bit is that I not only earned more, I'm also satisfied because I actually make stuff that people care about and I give work to 46 people (and still recruiting). When I travel through my region I still see the fruits of my work. I've now build my own 10 houses that are worth well over 2.5 million combined and they give me a 5% rent on its value (not counting the always increasing house prices) and also made it possible for other people (my coworkers/employees) to buy their own houses and send their own kids to college and safe for their own retirement.
       
      The weird thing is that I still like to thinker with computing and it's thanks to open source I still am able to thinker with computers in my free time, on rainy days.

    13. Re:40% of Silicon Valley's profits by Anonymous Coward · · Score: 1

      As much as MS may be a screw up. They put bread on the table.

      That's like labeling 100,000 new prison guard jobs a "good thing" because imprisoning more people puts "bread on the table".

      Sadly, this is what American Capitalism has turned into. We continue to reward even the worst models of profit.

    14. Re:40% of Silicon Valley's profits by robsku · · Score: 1

      =D

      --
      In capitalist USA corporations control the government.
  4. He's just changing robbers. by Anonymous Coward · · Score: 0

    From "Hi, I'm the EU and I'll be your robber." to "Hi, I'm the USG, and I'll be your robber."

    1. Re:He's just changing robbers. by Anonymous Coward · · Score: 0

      From "Hi, I'm the EU and I'll be your robber." to "Hi, I'm the USG, and I'll be your robber."

      Except the American robber can more easily be bought out than the EU robber.

    2. Re:He's just changing robbers. by Anonymous Coward · · Score: 5, Insightful

      If you want to live in a civilised society, taxes are the price you pay.

    3. Re: He's just changing robbers. by Anonymous Coward · · Score: 0

      Yup, the US robber is accountable to the voters, while the EU robbers are not accountable at all

    4. Re:He's just changing robbers. by Fwipp · · Score: 1

      "If you want to live in a a thieving, gangster, racketeering society for your statement to make some sense, taxes are the price you pay."

      I'm not sure that helped.

    5. Re: He's just changing robbers. by Anonymous Coward · · Score: 0

      I think you mean to say that the US robber is accountable to the lobbyists.

    6. Re:He's just changing robbers. by cyn1c77 · · Score: 1

      If you want to live in a civilised society, taxes are the price you pay.

      Funny, that's the same line the Mafia uses when offering protection!

    7. Re:He's just changing robbers. by FlyHelicopters · · Score: 1

      If you want to live in a civilised society, taxes are the price you pay.

      I suspect you don't quite know what your money goes towards, how much you really pay, and how much of it is really buying civilization...

      Ignorance is rampant, sadly...

    8. Re: He's just changing robbers. by Anonymous Coward · · Score: 0

      Taxes created by an unelected beaucracy in another country, and enforced against your wishes.

      Yeah. Totally civilized and not at all the justification for violent revolutions ever.

    9. Re:He's just changing robbers. by Required+Snark · · Score: 5, Insightful
      If you can't tell the difference between organized crime and a functioning democracy they you are deranged.

      You want freedom from government interference? Move to Somalia, central Mexico dominated by drug cartels or Southeast Asia where they grow opium. No "oppressive" government there.

      In contrast consider Norway. I've been there and it is one of the best run societies I have ever seen. Lot of government regulation and it always ranks near or at the top for overall quality of life.

      Since things in the US suck so much because of the "ebil gumment" why don't you "self deport" and go to one of the Libertard havens that exist all over the world? Since all problems result from government interfering with your precious sovereign liberty, you should be about to create a paradise on earth anywhere there is no effective central control. Parts of North Africa are lawless right now, and with the recent death of Uzbekistan's dictator I bet you and your best Libertarian buds could go over their and create the perfect society.

      Can you leave tomorrow? I'd be happy to drive you to the airport. Don't let the door hit your ass on the way out.

      --
      Why is Snark Required?
    10. Re:He's just changing robbers. by Anonymous Coward · · Score: 0

      If you want to live in a civilised society, taxes are the price you pay.

      It would seem then that we Americans are due a refund. After all, the current farce of a presidential election is many things, but civilized is definitely not one of them.

    11. Re:He's just changing robbers. by Anonymous Coward · · Score: 0

      "Why don't you move to Somalia"

      Why don't you move to North Korea?

    12. Re:He's just changing robbers. by smallfries · · Score: 1

      Nah, the mafia says "thats a really nice civilised society you got there. real shame if something bad were to happen to it". Not to be confused with their other greatest hit "Fuck you, pay me".

      --
      Slashdot: where don knuth is an idiot because he cant grasp the awesome power of php
    13. Re:He's just changing robbers. by Zontar+The+Mindless · · Score: 3, Interesting

      Sigh. There are many on the American right who try to lecture us on places they've obviously never been, based on a few factoids cherry-picked from Wikipedia.

      --
      Il n'y a pas de Planet B.
    14. Re:He's just changing robbers. by Gussington · · Score: 3, Insightful

      In summary, what works in Norway does not and will not work here in the United States,

      Because?

      unless you believe that the US government should be run entirely according to the culture, traditions and ideas of northern European white men. Funny, but that doesn't strike me as a very liberal idea and yet the liberals keep gushing about Norway. Go figure.

      There is a strong correlation between countries that use regulations to improve quality of life and succeed, and those that don't and don't. The American fascination with "freedom" is causing a lot of your problems.

    15. Re:He's just changing robbers. by Tesen · · Score: 1

      Can you leave tomorrow? I'd be happy to drive you to the airport. Don't let the door hit your ass on the way out.

      I have a minivan... I'll help shuttle them to the airport ;-)

    16. Re:He's just changing robbers. by Anonymous Coward · · Score: 0

      If you want to live in a civilised society, taxes are the price you pay.

      I suspect you don't quite know what your money goes towards, how much you really pay, and how much of it is really buying civilization...

      Big deal. Neither do you. Neither do you.

      Ignorance is rampant, sadly...

      Not quite ignorance, it's more exactly a diffuse situation where the cost of examining it to be fully understood is far in excess of the value of such an undertaking. Sociology and Economics is like that, it simply is not an understood mechanism where all the parts and pieces are clearly identified and their inter-workings established.

      If you REALLY wanted to come up with a true analysis of the price of civilization, you could try. But you aren't going to do so.

    17. Re:He's just changing robbers. by Anonymous Coward · · Score: 0

      Well, enlighten us with some peer reviewed sources. We can't just google it because all we get in the search results are liberatian bloggers.

    18. Re:He's just changing robbers. by Anonymous Coward · · Score: 0

      Can you leave tomorrow?

      Learn the Constitution, you insipid fuck, and you might figure out that it's your cuntdrizzly ass that needs to fuck out of our country.

    19. Re:He's just changing robbers. by Anonymous Coward · · Score: 0

      Fuck you pay me = traffic court.

    20. Re:He's just changing robbers. by Fwipp · · Score: 1

      I think you hit the wrong Reply button.

    21. Re:He's just changing robbers. by HuguesT · · Score: 1

      It does help that Norway is very rich from the oils it pumps form the North Sea. They do manage their wealth very well though.

    22. Re:He's just changing robbers. by Gussington · · Score: 3, Interesting

      But it's not just Norway is it?
      If you ever keep an eye on those OECD comparison things, there's a whole host of countries that do consistently better than the US on education, health, crime, corruption, social welfare, life expectancy etc. So take Norway out, let's compare Sweden, Denmark, Netherlands, France, Germany, UK, Ireland, Iceland, Canada, Australia, New Zealand, Hong Kong, Singapore, Japan etc etc and you will see a strong correlation between appropriate regulation and quality of life.
      Conversely if you look at the worst places in the world, Somalia, Sierra Leone, Afghanistan etc they all have next to no rules, you can do what ever you an get away with and the people suffer as a consequence.
      The US is the richest nation on earth with the most abundant natural resources. It should win at everything, but it doesn't.
      Why do you think that is?

  5. Nice by Anonymous Coward · · Score: 0

    Only now that they are cracking down on expatriating for tax evasion

  6. I'll believe it when I see it by ArtemaOne · · Score: 1

    I find this a bit hard to swallow.

    1. Re:I'll believe it when I see it by Anonymous Coward · · Score: 0

      You get used to it.

    2. Re:I'll believe it when I see it by Anonymous Coward · · Score: 0

      Apples Irish tax heaven just turned into a 14 billion tax hell. They will most likely officially move their profits to the U.S. for both goodwill and government backing until the Irish situation is resolved and they have a new lawless hole to register/wash their profits in. In other words those profits he speaks of actually exist, until now Apple just had a way to avoid paying taxes on them.

    3. Re: I'll believe it when I see it by Anonymous Coward · · Score: 0

      You didn't have any problem swallowing my nut last night

    4. Re:I'll believe it when I see it by alvinrod · · Score: 1

      That's unlikely given that the U.S. tax rate is far worse than the Irish rate and it would cost Apple far less to leave the money in Ireland even when (even without the ruling the loophole Apple was exploiting would only last until 2020) they're not getting the sweetheart rate they have in the past.

    5. Re:I'll believe it when I see it by Anonymous Coward · · Score: 0

      That's what she said.

    6. Re:I'll believe it when I see it by Anonymous Coward · · Score: 0

      You've been swallowing Apple's tapioca this long, I'm sure you won't have any problems.

    7. Re: I'll believe it when I see it by Anonymous Coward · · Score: 0

      Not necessarily. If the EU ruling stands some EU countries (e.g. Germany) will start back-taxing on profits "evaded" from their countries. Effectively wirh the EU decision Europe as a whole has turned into a tax hell for US companies. The result will be that their European subsidaries will pay hefty license charges to their US headquarters on any and all sales, amounting to maybe 95% of gross margin. Eeat that EU commissionars!

      Of course it also means US companies will reduce or stop investing in R&D in EU countries because these efforts are entirely financed from profits after tax. Talk of unintended consequences...

      The whole story shows the utter stupidity and incompetence of the self-proclaimed EU "elite" - what a bunch of morrons. History will not be kind to them.

    8. Re: I'll believe it when I see it by jabuzz · · Score: 1

      Apple Ireland has never evaded taxes in Germany or any other EU country. Any company registered in one EU state is perfectly entitled to operate in all other EU states and book their profit in the country that they are resident.

      The problem is for Apple is they negotiated a special rate with Ireland so that they paid the 12.5% on the profits made in Ireland but nothing on the profits made in the rest of the EU.

      As this deal was not generally available the EU has correctly ruled that it broke the state aid rules, and are requiring Ireland to collect the take from the 10 years prior to the investigation starting; that was 2013, so from 2003 to present day at the standard 12.5% rate for all the profits that Apple made in the EU not just those in Ireland.

      Ireland and Apple are of course going to appeal to the European Court of Justice (the highest court in the EU that rules on these things) and when they inevitably loose Apple will have to pay up, or face sanctions.

      Repatriating money to the USA will not help Apple not pay the bill. Whether the US government allows the bill as writeoff is down to them, but Apple sold products through Apple Ireland, and booked the profit there, they have to pay the appropriate rate of tax on those profits which is 12.5%.

      Oh and transfer pricing is already illegal in the EU so charging 95% licensing fees will get you into hot water as well.

      The prudent thing for the Irish government to do is bitch about having to collect it, but when they do use the money to pay down the national debt. Should shave about 5% off the total, which is currently 203 billion Euro.

    9. Re:I'll believe it when I see it by Anonymous Coward · · Score: 0

      thats what his boyfriend said...

  7. How does it contradict? by SuperKendall · · Score: 1

    Obviously Cook is planning that taxes are lower for corporations next year, or that Apple will get a break for bringing back the taxes - either condition would meet his statement that Apple would not re-patriate because taxes are too high.

    What large-corperation loving candidate is very likely to win the election and be in office next year to make that happen, hmm...

    --
    "There is more worth loving than we have strength to love." - Brian Jay Stanley
    1. Re:How does it contradict? by DoofusOfDeath · · Score: 1

      Obviously Cook is planning that taxes are lower for corporations next year, or that Apple will get a break for bringing back the taxes - either condition would meet his statement that Apple would not re-patriate because taxes are too high.

      What large-corperation loving candidate is very likely to win the election and be in office next year to make that happen, hmm...

      Both of them?

    2. Re:How does it contradict? by El+Cubano · · Score: 1

      What large-corperation loving candidate is very likely to win the election and be in office next year to make that happen, hmm...

      As both major candidates love large corporations (albeit different large corporations), could you be more specific? I say that because Apple is one of those companies that inhabits multiple spaces, some of which have been associated with the left and others which have been associated with the right.

    3. Re:How does it contradict? by tomhath · · Score: 1

      Taxes in the US are already lower than the EU. If Apple has to pay taxes they may as well bring the cash home.

    4. Re:How does it contradict? by reboot246 · · Score: 1

      It sounds like Cook is anticipating a Trump win. Hillary certainly would go the other way on taxes.

    5. Re:How does it contradict? by Anonymous Coward · · Score: 2, Informative

      That is incorrect, the US has the third highest corporate income taxes in the world at 39%. Europe's average is 26%.

      http://taxfoundation.org/article/corporate-income-tax-rates-around-world-2015

    6. Re:How does it contradict? by fluffernutter · · Score: 4, Informative

      You talk like they actually pay that rate.

      --
      Laws are rules for the court, but merely a bottom bar to hit for life. Think beyond laws in your actions always.
    7. Re:How does it contradict? by Anonymous Coward · · Score: 2, Insightful

      And also lower than they were in most of the 20th century. If corporations paid higher taxes in the US, maybe we could have fewer mentally ill homeless pooping at the bus stop. Maybe we could have better public education. Maybe we could have a social safety net. Maybe we could have federal funding for... oh never mind, this is slashdot.

    8. Re:How does it contradict? by Anonymous Coward · · Score: 0

      What large-corperation loving candidate is very likely to win the election and be in office next year to make that happen, hmm...

      You wish. When Trump wins Tim Cook will be on the other side of the Wall BEGGING to pay taxes and be let back in.

    9. Re:How does it contradict? by Anonymous Coward · · Score: 0

      And also lower than they were in most of the 20th century. If corporations paid higher taxes in the US, maybe we could have fewer mentally ill homeless pooping at the bus stop. Maybe we could have better public education. Maybe we could have a social safety net. Maybe we could have federal funding for... oh never mind, this is slashdot.

      A few special cases in the tax code to temporarily boost things that are a net good for the country are fine, but they need to be temporary. Our tax code doesn't need higher corporate taxes. It needs fewer ways to get out of paying them at all.

      As an example, Boeing pays federal taxes about a fourth of the time due to all of that junk...

    10. Re: How does it contradict? by Anonymous Coward · · Score: 0

      Mental health isn't a funding problem. The ACLU convinced e Supreme Court (right or wrong) that sending the insane to asylums was detention without a trial, and consequently, there is only a trivial ability force the mentally ill to accept help. Unfortunately, many mentally ill people do not recognize that they have an illness and are unwilling to get help. Fortunately, the Democrats brilliantly blamed Reagan for defunding mental institutions instead of the court's decision, so the whole "no funding for mental health" trope lives on.

    11. Re:How does it contradict? by Anonymous Coward · · Score: 0

      Rounding up and locking away the homeless would work wonders for getting them out of our bus stations and subways. Also would be something to do with the prisons once the war on drugs has ended. Win-win?

    12. Re: How does it contradict? by Anonymous Coward · · Score: 1, Insightful

      No, mental health is 100% a funding problem. The issue is that we were sending the mentally ill to asylums without due process and weren't providing other options either. So, the choice came between detaining people illegally or letting them roam loose without any help.

      Only an imbecile would think that there aren't any steps in the middle. The correct thing to do would have been to provide funding to things like community clinics, halfway houses and to ensure that those that might need to be institutionalized were processed in an expedient manner.

      The problem wasn't the ACLU, the problem was cheapskate conservatives who didn't and don't value human life.

    13. Re: How does it contradict? by Anonymous Coward · · Score: 0

      Oh great tax expert, do tell me what exactly I can use to write off foreign profits. Let me give you a hint. One of our kleptocracies great "fuck you's" to industry is that there is little you can do to protect money you mad overseas from their taking ways.

    14. Re: How does it contradict? by Imbrondir · · Score: 3, Insightful

      I`m no tax expert but I believe it`s done like this:

      • 1) Buy services or import overpriced goods from a business you own in a tax haven.
      • 2) Scale the above till you barely profit in the high tax country, but have massive profits in the low tax country
      • 3) Pay low income taxes in the low tax country
      • 4) Profit!

      I believe you will not have to pay income taxes more than once. At least as long as you keep the money in the business set up in the low tax country.

    15. Re:How does it contradict? by rtb61 · · Score: 1

      Really it is just an indication of psychopathic greed panic. Basically the entire economic system looks to be shifting to tax payable at point of revenue and no shifting allowed. Can't prove your costs with tax records from other countries than pay full rate tax on total income with no deductions. Hence they are now looking to shift tax burdened money before it kicks in. Catch if they are to abusive about it, those countries ending up with those taxes without being the revenue source will be considered parasites and it will cause them large problems in the future.

      --
      Chaos - everything, everywhere, everywhen
    16. Re: How does it contradict? by Anonymous Coward · · Score: 0

      It's called fleeing while you still can. They will remove large swashes of their back office operations in Europe and move it elsewhere. Profits will be channelled back to the US as fast as possible. Far too risky to keep em profits accessible to the praying eyes of EU politicians. They obviously don't even shy back from breaking long and well established legal ground rules such as that law can not be applied retroperspectively. Not a friendly business environment.

    17. Re: How does it contradict? by Anonymous Coward · · Score: 0

      Oh great tax expert, do tell me what exactly I can use to write off foreign profits. Let me give you a hint. One of our kleptocracies great "fuck you's" to industry is that there is little you can do to protect money you mad overseas from their taking ways.

      Pussy boy, US citizens must by law declare all income from all sources on a global basis. Why should corporation be able to evade taxation on their earnings? /. has turned into a haven for millennials and "social justice warriors."

    18. Re: How does it contradict? by Anonymous Coward · · Score: 0

      Exactly.

    19. Re: How does it contradict? by Anonymous Coward · · Score: 0

      Your comment makes the most sense of anything ever written in human history. I believe a single group is responsible for all of society's ills... that group are the Children of Israel who are responsible for Joe Bien's War on White Men. Firmly, the J3W$ did WTC.

    20. Re: How does it contradict? by EvilAlphonso · · Score: 1

      They obviously don't even shy back from breaking long and well established legal ground rules such as that law can not be applied retroperspectively. Not a friendly business environment.

      State subsidies have been illegal in the common market since the Treaty of Rome in 1958, when Steve Jobs was 3... so we can safely say the law in question predates the birth of Apple. Ireland joined the EEC before Apple incorporated, so we can safely say that Ireland already had to obey those laws before Apple incorporated. Apple started operating in Ireland 7 or 8 years after Ireland joined the EEC, so the sweet deal Apple negotiated in Ireland has always been illegal. So illegal, in fact, that Ireland itself was phasing that sort of deal with a deadline of 2020. The US also has a legitimate interest in the Irish tax games as the US Senate seems to think that Apple Inc used it to dodge $11bn a year in US taxes between 2009 and 2013 (the year the senate report came out).

    21. Re: How does it contradict? by Anonymous Coward · · Score: 0

      As an MBA let me say, you may not be a tax expert but you are exactly correct. The only thing you really missed was that much of the money paid to the foreign subsidiary is for licensing, e.g. permission to use Nike's swoosh emblem.
      This is all called transfer pricing.

    22. Re:How does it contradict? by Anonymous Coward · · Score: 0

      Both of them are corrupt as hell. I see no reason to why Apple can't buy tax laws from either of them.

    23. Re:How does it contradict? by Anonymous Coward · · Score: 0

      Why should I pay for your "safety net"? Pay for it yourself/your family's... or get charity.

  8. plans to by turkeydance · · Score: 1

    not will

  9. Not a contradiction by Anonymous Coward · · Score: 0

    The tax bill in both the House and Senate reduces business taxes to between 15-20% from the current 35-38% federal (Apple pays about 25-30% after deductions for R&D and energy rebates). The rate to bring back funds is currently at those 35%+ rates and will be reduced to 8-10% if any elected candidate signs the already passed bills. They technically will have to repass the bills for the next congress.

    If I post this to MacRumors I will be BANNED because it touches on the subject of poly-tics (many blood sucking insects).

  10. Lies by Anonymous Coward · · Score: 0

    An interesting side-note: Apple accounts for 40% of Silicon Valley's profits.

    Completely untrue. Apple may well account for 99% of Ireland's profits but they don't account for any significant amount in Silicon Valley. Until next year, maybe, unless they can cut a better deal elsewhere.

  11. Brilliant! by Anonymous Coward · · Score: 0

    A transition from a future convicted tax evador to a national hero whose taxes will save the nation's social security and educatio^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h^h military-industrial complex.

  12. I disagree with the term "back" by UnknowingFool · · Score: 3, Interesting

    Apple is not bringing "back" profits. That money was never in the US. The money that is in question is profit Apple made on sales overseas in the EU. If the US chose to bring the money into the US, the tax rate would be probably 35% at the top rate. So Apple kept the money overseas and never moved it. Part of it is for operations overseas. Part of it was the tax rate the US would charge.

    --
    Well, there's spam egg sausage and spam, that's not got much spam in it.
    1. Re:I disagree with the term "back" by naughtynaughty · · Score: 2, Insightful

      The money certainly was "in the US". iPhone sales in the US result in profits in Ireland, substantial profits.

    2. Re:I disagree with the term "back" by Anonymous Coward · · Score: 0

      As if apple's money is ever going to be taxed properly (be it anywhere shockingly doesn't matter if "it's in" Ireland or the USA) and somehow benefit the working "middle" class with lower taxes for a more solid real middle class and not a "pretend we're not in debt" and chase that american dream! Proper taxation to big corporations would finally bring appropriate and decent healthcare for all american citizens and other basic needs of society, perhaps the water infrastructure, no?

      The USA has plenty of tax havens in several states, Nevada, Delaware, South Dakota, Wyoming as a few of the most known. Until tax havens and all these fuckery euphemisms used such tax loopholes/evasion/optimization are dealt with harshly by putting some CEO's of banks, corporations (LLC's and what not) in heavy fines and jail time nothing is going to change.

      edit: as usual funny captcha AI throws an ironic one - gullible - as in me? right....i wish.

    3. Re:I disagree with the term "back" by magarity · · Score: 3, Interesting

      Apple is not bringing "back" profits. That money was never in the US

      More Apple shareholders are in the US than elsewhere. In finance terminology, profits are "brought back" to the owners. So the term is correct in this usage.

    4. Re:I disagree with the term "back" by Anonymous Coward · · Score: 0

      How do you know for sure? Transfer pricing means they have "off-shore" (probably sitting in a bank in Nevada) profits.

    5. Re:I disagree with the term "back" by dprimary · · Score: 1

      US profits do not go through Ireland, only EU profits do.

    6. Re:I disagree with the term "back" by alantus · · Score: 2

      edit: as usual funny captcha AI throws an ironic one - gullible - as in me? right....i wish.

      This must be a new thing, I didn't know Slashdot allowed editing posts after submitting!

      edit: as suspected, it doesn't.

    7. Re:I disagree with the term "back" by Anonymous Coward · · Score: 0

      It doesn't but you can edit after seeing the captcha, before you post.

      http://i.imgur.com/DIRIlrM.png

      Notice that the captcha is visible, but I can still go back and edit the post (in fact, that's what I'm doing right now).

    8. Re:I disagree with the term "back" by dbIII · · Score: 4, Insightful

      Actually it was in the US.
      Look up "transfer pricing".
      It's where things happen like Apple USA buy an iPhone from Apple EIRE at very close to retail price and so on paper make almost zero profit in the USA.
      The profit then happens in Ireland where the difference between say $10 per unit and $500 per unit is not taxed much at all due to personal agreements with Irish politicians and some other financial games involving Holland.


      The EU is extremely pissed off because they have been propping up Ireland financially while Ireland has been looking the other way at vast amounts of tax revenue that Irish laws say they should be collecting. It's not about 6000 jobs (the usual excuse and most likely an outright lie about the number Apple employ in Ireland), the unpaid taxes could provide that a hundred times over, it would be a money trail leading into the pockets of those Irish politicians who are loudly damning the EU this week for suggesting they tax Apple.

    9. Re:I disagree with the term "back" by thegarbz · · Score: 1

      It's not about 6000 jobs (the usual excuse and most likely an outright lie about the number Apple employ in Ireland)

      You don't think a company the size of Apple employs 6000 accountants?

    10. Re:I disagree with the term "back" by Anonymous Coward · · Score: 0

      Not 6000 accounts - lawyers, probably yes.

    11. Re:I disagree with the term "back" by swillden · · Score: 1

      iPhone sales in the US result in profits in Ireland

      Cite?

      --
      Note to ACs: I usually delete AC replies without reading them. If you want to talk to me, log in.
    12. Re:I disagree with the term "back" by Anonymous Coward · · Score: 0

      edit: as usual funny captcha AI throws an ironic one - gullible - as in me? right....i wish.

      This must be a new thing, I didn't know Slashdot allowed editing posts after submitting!

      edit: as suspected, it doesn't.

      When you edit as anonymous coward you get your CAPTCHA at the point you preview. Then you can go back and edit.

      CAPTCHA: "actually" - You see Slashdot has indeed perfected AI. I think there is a bug which swapped the random CAPTCHA system round with the editing system. It would explain mainy things.

    13. Re:I disagree with the term "back" by Anonymous Coward · · Score: 0

      It's not about 6000 jobs (the usual excuse and most likely an outright lie about the number Apple employ in Ireland)

      You don't think a company the size of Apple employs 6000 accountants?

      No. They outsource it, like everything else. Do you really think apple actually employs a single person making apple hardware?

    14. Re:I disagree with the term "back" by dbIII · · Score: 1

      You don't think a company the size of Apple employs 6000 accountants?

      I'm describing their operations in Ireland where they have a "paper presence", please try to keep up.

    15. Re:I disagree with the term "back" by Pascal+Sartoretti · · Score: 1

      More Apple shareholders are in the US than elsewhere

      Source ?

    16. Re:I disagree with the term "back" by thegarbz · · Score: 1

      I'm making a sarcastic remark to the state of the workforce of companies in tax havens. Do keep up yourself.

    17. Re:I disagree with the term "back" by dbIII · · Score: 1

      If you are not being serious and not informing others of the fact I do not see how you can be critical just because others cannot tell the difference between you pretending to be stupid and the real thing.

    18. Re:I disagree with the term "back" by UnknowingFool · · Score: 1

      Um, no. Apple sells the iPhone in Europe. It generates profits in Europe. Apple also sells the iPhone in the US. Those profits have not mixed. Please look this up.

      --
      Well, there's spam egg sausage and spam, that's not got much spam in it.
    19. Re:I disagree with the term "back" by UnknowingFool · · Score: 1

      More Apple shareholders are in the US than elsewhere. In finance terminology, profits are "brought back" to the owners. So the term is correct in this usage.

      What do the overall profit of a multinational have to do with how it deals with subsidiaries? In this case, nothing at all. Apple notes the profits it made in different subsidiaries but does not mix the money. That's like saying a millionaire isn't one in the US because he/she keeps some money overseas.

      --
      Well, there's spam egg sausage and spam, that's not got much spam in it.
    20. Re:I disagree with the term "back" by UnknowingFool · · Score: 1

      It's where things happen like Apple USA buy an iPhone from Apple EIRE at very close to retail price and so on paper make almost zero profit in the USA.

      Er what? Apple records and notes huge US profits on the iPhone so that alone destroys your argument.

      --
      Well, there's spam egg sausage and spam, that's not got much spam in it.
    21. Re:I disagree with the term "back" by UnknowingFool · · Score: 1

      I'm describing their operations in Ireland where they have a "paper presence", please try to keep up.

      So you're saying 5,500 employees is a "paper presence". Why don't you do some research before making such an easily provable lie./P

      --
      Well, there's spam egg sausage and spam, that's not got much spam in it.
  13. The cynic by Anonymous Coward · · Score: 0

    ... plans to bring back billions of dollars in profit to the U.S. ...

    Given the habit of multinationals to rort US taxation and labour laws, the cynic in me thinks they've found another loophole or captured another government department.

    http://www.cityprofile.com/forum/attachments/national-politics-debate/40633d1320853833-death-personhood-corpos.gif

    See also: https://philosophersforchange.org/2014/02/11/takeover/

  14. if charity, dangerous by fche · · Score: 1

    If this move turns out to be contrary to the fiduciary interests of shareholders, expect a class action lawsuit. A CEO can't simply throw money away.

    1. Re:if charity, dangerous by Anonymous Coward · · Score: 0

      Yeah, remind me - what was the name of that CEO who got successfully sued because the company paid its taxes. I think it was either the Tooth Fairy or the Easter Bunny.

    2. Re:if charity, dangerous by Anonymous Coward · · Score: 0

      Let's hope Tim sees your comment. You may have just saved him and Apple's army of lawyers and accountants from making a terrible mistake.

    3. Re: if charity, dangerous by Anonymous Coward · · Score: 0

      You, and many others, should actually learn whoa fiduciary duty means before attempting to converse about it. I will be nice and simply point out that you are entirely (not just a little) wrong. You're getting info from bad sources or stupid people. Wikipedia has a fine article on this very subject. Cornell does but I am on a tablet. Try Google... Really, read up on it. It is nothing like you seem to think. There are a lot of you who seem to think that way. I am really curious where the misinformation is coming from and why.

  15. B-B-B-But... by mutantSushi · · Score: 2

    Isn't that profit rightly produced in Ireland? Or was that in the Bermuda Triangle? At least Ireland will get their cut of the imaginary Irish profits (when forced by EU to assess legal tax rate on Apple's Irish subsidiary.) Longer term, countries where profits are made will want to see their rightful tax, e.g. as Austria'a position. Curious though, what these tax scams, offshore domiciling etc, imply when assessing trade treaties etc. I mean, by the "supposed" numbers, Ireland has a certain benefit of trade, even though that is untaxed Apple money. If those anomalies are removed, wouldn't that substantially change the over-all picture of trade benefits? (trade treaties are conventionally concluded on basis of mutual benefit) Bigger picture, is the number of "high tech" companies etc, benefitting from tax avoidance, and the distortion effect that creates, effectively subsidizing them vs. other businesses who would otherwise compete for investments, never mind "high tech" products which wouldn't be viable at all if not avoiding taxes.

    1. Re:B-B-B-But... by JamesTRexx · · Score: 1

      I had a discussion about this just this evening with a friend. He states the EU shouldn't charge that amount to Apple, but to Ireland itself since it's Ireland that struck a bargain with Apple.
      I agree on part of it, but Ireland could never pay that amount, certainly not on the backs of the Irish. They'd take the first boat to leave the country if the government did that so it's a bit more obvious to make Apple pay who should have known a low tax rate as they had could never have been correct.

      I think Tim left out after saying he'd bring back those profits to the US that they'd end up in another deal and loophole and stay safe an sound on the Apple bank account.

      --
      home
    2. Re:B-B-B-But... by fluffernutter · · Score: 1

      According to current CNN article, the profits were from Europe, Middle East, Africa, India.

      --
      Laws are rules for the court, but merely a bottom bar to hit for life. Think beyond laws in your actions always.
    3. Re:B-B-B-But... by Rakshasa+Taisab · · Score: 1

      Actually it doesn't really matter _that_ much if it's Apple Ireland or the Country Ireland that gets charged with 13 billion in taxes... either case will fuck up both Apple and the government. (for the better)

      --
      - These characters were randomly selected.
    4. Re:B-B-B-But... by Anonymous Coward · · Score: 0

      I saw that the EU was eyeing this money to tax it. Maybe they are moving it to prevent the higher EU taxes from being applied and pay a slightly lower american tax. And just get it back to the US where they can make better use of it. And since it would be going to the american system to take care of the american people.. This is a good move on Apple all around. and american company being responcable to the american system that allowed them to create these products and be the largest company on the stock exchange. There are so many ways to spin this as good and it is good.

    5. Re: B-B-B-But... by Anonymous Coward · · Score: 0

      $13B fuck up Apple? You so funny. That's about 1 months profit, even at the currently reduced rate of earning. They can pay that out of the petty cash account...

    6. Re:B-B-B-But... by dbIII · · Score: 1

      I had a discussion about this just this evening with a friend. He states the EU shouldn't charge that amount to Apple, but to Ireland itself

      Huge flaw in that - since the EU is financially propping up Ireland they would be charging themselves!

    7. Re: B-B-B-But... by Anonymous Coward · · Score: 0

      The EU's corporate tax rates are generally lower than those of the USA and the US tax rate for repatriated profits is nominally the US rate less the rate already paid.

    8. Re: B-B-B-But... by Anonymous Coward · · Score: 0

      then they should just pay it and shut up with their fake indignity about the whole thing. they can just raise the price of iphones and make the money back

  16. Re:rats fleeing the sinking ship by surfdaddy · · Score: 0

    Stolen? Please elaborate.

  17. Tactical Move by ytene · · Score: 3, Interesting

    This announcement makes perfect sense if you think of it as a move in the game of chess between Apple and the EU.

    Despite his public proclamations and rhetoric, Tim Cook knows that the EU investigation into the tax deal between Ireland and Apple is absolutely not, "political crap" and he's had now enough time for his lawyers to tell him so. That event is an issue between the EU and Ireland and, in a sense, has nothing to do with Apple. The problem for Cook, then, is what to do? He can't put Apple in the middle of the dispute with the EU. He has no options.

    Except one.

    He can go to the US government to ask for help. "Hey Barak, that sweet deal we had with Ireland, the one that is letting us be profitable and employ lots of Americans? It's going south. Can you help?"

    Obama isn't stupid either. He knows that now that the wheels are in motion, Apple is going to have to pay some taxes to someone - and Obama would rather the someone was the US Federal Government and not the Irish government. So what we're seeing now is Apple asking Washington for help. Washington have said, "Sure, we can help. But of course you're going to have to pay some tax somewhere..."

    So Tim Cook has made this announcement about repatriation to show Barak that he's serious. Washington will now attempt to apply pressure to Brussels in order to get the EU to back down and allow Apple to continue to operate across the EU, all whilst paying less than 1% Corporation Tax. Meanwhile, Apple will repatriate some of their profits, which the US will tax, as part of the arrangements.

    At least, that's their plan. However, bear in mind that the EU are just in the process of throwing out TTIP, which is going to make any attempt by the US to negotiate forcefully absolutely fraught with danger. The worst possible thing would be for the US to try and apply pressure right now: all they will do is make the entire EU mad at them. The only potential ally they would have had, the UK, is in the process of leaving the EU [with the planned start of Article 50 to commence in the New Year].

    But the thing that all us little people need to remember here is that every pound, euro or dollar in tax that Apple "avoids", well that's a pound, euro or dollar that we have to find. When companies don't pull their weight, tax-wise, the private individuals are the ones who get stung. You only need to look at the international tax arrangements of the big multinationals to realise what a joke this process has become. What we need is a clear, internationally-agreed law that says that for tax purposes, a transaction occurs at the location that the buyer initiates the transaction. [ Turning that around, and saying that it is where the seller processes the transaction achieves nothing: Apple and others would just put their transaction processing system in a tax haven ].

    The interesting thing is that these practices cost "local" tax payers HUGE amounts of extra taxes. So it's entirely possible that what we're seeing here could set a precedent that benefits 500 million people across the EU... Let's hope so...

    1. Re:Tactical Move by PPH · · Score: 1, Troll

      Right. It's a three-way game. Apple will bring back 'a few billion'. Which, if taxed at 10 or 20% (nobody with a competent accountant pays the full marginal US rate of 35%), that will cost them a few hundred million. Small potatoes to have the US Treasury arm-twist the EU to BTFO. The USA would like to have Apple repatriate their offshore cash. Not just for the taxes, but to improve the odds that if Apple chooses to make investments, they will make them here. The EU might have shot themselves in the foot, big time, by going after Apple. Because if laws and regulations over there are subservient to "We needs the money!" thinking, that's not a place I'd like to risk expanding my business. And I suspect Apple will think the same.

      every pound, euro or dollar in tax that Apple "avoids", well that's a pound, euro or dollar that we have to find.

      One can legally "avoid" taxes (evasion is another issue, but not in the current case involving Apple). And the idea that "we" (whoever "we" is) have to have that money is faulty logic. We have to live within our means. And if we drop to the level of manipulating laws or regulations to get money that isn't legally owed, the whole rule of law system we live under falls apart pretty quickly.

      --
      Have gnu, will travel.
    2. Re:Tactical Move by drinkypoo · · Score: 1

      This announcement makes perfect sense if you think of it as a move in the game of chess between Apple and the EU.

      It does, or you can just see it as a simple strategic decision. The EU wants them to start paying taxes; if they're going to have to pay them somewhere, they might as well pay them in the USA. Then they can employ more people here (and less in the EU) which is a benefit since their primary engineering is all here in the USA. They were one of the pioneers of the double irish accounting system, it's "made" them a lot of money, and now that it's over it's only a drawback to employ people in Ireland. It's much easier to fuck over workers in the USA.

      --
      "You're right," Fisheye says. "I should have set it on 'whip' or 'chop.'"
    3. Re:Tactical Move by Anonymous Coward · · Score: 0

      As if apple's money is ever going to be taxed properly (be it anywhere shockingly doesn't matter if "it's in" Ireland or the USA) and somehow benefit the working "middle" class with lower taxes for a more solid real middle class and not some pretend we're not in debt for now and chase that american dream!

      Proper taxation to big corporations would finally bring appropriate and decent healthcare for all american citizens and other basic needs of society, perhaps the water infrastructure, no?

      But unfortunately the USA has plenty of tax havens in several states, Nevada, Delaware, South Dakota, Wyoming as a few of the most known. Until tax havens and all these fuckery euphemisms used such tax loopholes/avoidance/evasion/optimization are dealt with harshly by putting some CEO's of banks, corporations (LLC's and what not) in heavy fines and jail time nothing is going to change, wherever the money is taxed in (and lets be frank and clear, their tax rate is a joke akin to shitting down the throats of every "middle" class "blue collar" worker), society in general won't benefit a single $/€.

      But rest assured politicians unlike the rest will still be super-pack'ed *wink*wink* working hard to keep (or make) America the greatest country on earth (again).

    4. Re:Tactical Move by ShakaUVM · · Score: 2

      This is actually a big part of Trump's plan for his presidency. Tax holiday, bring back the billions Apple and Microsoft have stashed overseas, and put the money to work inside of America as well.

      It's well known that they're just waiting for a tax holiday to do this, so Obama could theoretically steal some of Trump's fire in the unlikely event it looks like he's going to win and do it early.

    5. Re:Tactical Move by pla · · Score: 2

      It makes even more sense when you consider that the US credits companies for taxes paid to other countries.

      Effectively, the EU's decision lets Apple repatriate roughly $50B, tax free.

    6. Re:Tactical Move by Feral+Nerd · · Score: 1

      This announcement makes perfect sense if you think of it as a move in the game of chess between Apple and the EU.

      Despite his public proclamations and rhetoric, Tim Cook knows that the EU investigation into the tax deal between Ireland and Apple is absolutely not, "political crap" and he's had now enough time for his lawyers to tell him so. That event is an issue between the EU and Ireland and, in a sense, has nothing to do with Apple. The problem for Cook, then, is what to do? He can't put Apple in the middle of the dispute with the EU. He has no options.

      Except one.

      He can go to the US government to ask for help. "Hey Barak, that sweet deal we had with Ireland, the one that is letting us be profitable and employ lots of Americans? It's going south. Can you help?"

      Obama isn't stupid either. He knows that now that the wheels are in motion, Apple is going to have to pay some taxes to someone - and Obama would rather the someone was the US Federal Government and not the Irish government. So what we're seeing now is Apple asking Washington for help. Washington have said, "Sure, we can help. But of course you're going to have to pay some tax somewhere..."

      So Tim Cook has made this announcement about repatriation to show Barak that he's serious. Washington will now attempt to apply pressure to Brussels in order to get the EU to back down and allow Apple to continue to operate across the EU, all whilst paying less than 1% Corporation Tax. Meanwhile, Apple will repatriate some of their profits, which the US will tax, as part of the arrangements.

      At least, that's their plan. However, bear in mind that the EU are just in the process of throwing out TTIP, which is going to make any attempt by the US to negotiate forcefully absolutely fraught with danger. The worst possible thing would be for the US to try and apply pressure right now: all they will do is make the entire EU mad at them. The only potential ally they would have had, the UK, is in the process of leaving the EU [with the planned start of Article 50 to commence in the New Year].

      But the thing that all us little people need to remember here is that every pound, euro or dollar in tax that Apple "avoids", well that's a pound, euro or dollar that we have to find. When companies don't pull their weight, tax-wise, the private individuals are the ones who get stung. You only need to look at the international tax arrangements of the big multinationals to realise what a joke this process has become. What we need is a clear, internationally-agreed law that says that for tax purposes, a transaction occurs at the location that the buyer initiates the transaction. [ Turning that around, and saying that it is where the seller processes the transaction achieves nothing: Apple and others would just put their transaction processing system in a tax haven ].

      The interesting thing is that these practices cost "local" tax payers HUGE amounts of extra taxes. So it's entirely possible that what we're seeing here could set a precedent that benefits 500 million people across the EU... Let's hope so...

      You seem to be trying to make the case that all Apple thinks all it has to do is move all it's billions to the US, play the US off against the Europeans and their piles of cash will be safe from the EU. Even if that assessment is true I'm having trouble believing that the US leadership can possibly be that short sighted since it would sour their relationship with a whole string of their oldest and most important allies (although I have no trouble believing President Trump would be that stupid). Apple (along with a whole bunch of other corps) has the problem that they have used these questionable methods to get out of paying taxes in the EU and US for years but now the displeased citizenry both in the EU as well as the US has lit some major fires under the collective asses of their elected leaders they are finding they racked up a huge bill. If Apple tries to play off

    7. Re:Tactical Move by superfast-scooter · · Score: 1

      Or maybe this - "Vestager said if Washington chose to tax the profits reported by Apple's Irish operation, she would reduce her demand accordingly."

      See: http://www.reuters.com/article...

    8. Re:Tactical Move by FlyHelicopters · · Score: 0

      Obama isn't stupid either.

      While I agree with some of your points, I actually disagree with this one...

      Obama has shown for 7.5 years that he is rather stupid indeed... Oh I'm sure he is book smart, but in terms of real world, he is a complete moron...

    9. Re:Tactical Move by smallfries · · Score: 1

      No, the current issue is evasion. Apple evaded taxes by declaring them in an imaginary company that was not based in any country on earth. They did this solely for the purpose of tax evasion.

      Ireland is not free to choose its own tax laws (which would have made it a "sweetheart deal" rather than an illegal subsidy). Apple broke the law of the EU (which is the highest sovereign power in Ireland). The money is legally owed - to the EU, and one provision in the deal is that if Ireland does not take it the other countries of the EU where Apple products were sold can claim the money for themselves.

      --
      Slashdot: where don knuth is an idiot because he cant grasp the awesome power of php
    10. Re:Tactical Move by AmiMoJo · · Score: 1

      Is no candidate proposing to simply start taxing profits held overseas? Less whatever tax they paid overseas of course.

      --
      const int one = 65536; (Silvermoon, Texture.cs)
      SJW, n: "Someone I don't like, and by the way I'm a fuckwit" - AC
    11. Re:Tactical Move by Anonymous Coward · · Score: 0

      What we need is a clear, internationally-agreed law that says that for tax purposes, a transaction occurs at the location that the buyer initiates the transaction.

      A very interesting comment. I agree wholeheartedly with the sentiment, and i even agree with your proposed law. However:

      In Ireland (or anywhere!), Apple starts a MAIL-ORDER-ONLY company that sells Every Single Product for 1 Dollar / Euro / Rock.
        (It's Crazy Eddie!) It's real, it's warranted, the whole bit. That solves the tax problem as there now *IS* almost nothing to collect.

      Corporate profit? Oh, that comes just the shipping and handling and insurance. You have just NO IDEA what handling costs now-a-days, it's incredible. And gee -- that's not really profit, it's only part of our internal overhead so that we can keep our prices so low. And no, you can't stop by the store to pick a few thousand up.

      Oh, the handling charges got "lawed out"? Well there's our internal, funny money shipping-between-warehouses fees that we have to charge for. Or storing the boxes they come in. Or we're self-hosting our own insurance and we make the user cover 100% of the potential loss while shipping. Oh but don't worry, we'll think of SOMETHING. After all, that's someone's job; and as long as they save more than they cost they're still worth it.

      It's a game with Big Bucks and Big Profit. Paying taxes is evil and a profit inertia, you should avoid it wherever possible. OTOH governments should STOP supporting anything and everything under the sun. If they didn't SPEND so much they wouldn't have to COLLECT so much in the first place.

      The public (whichever public you want) is NOT a Cash Cow, even though most legislatures treats it as such. And given enough legal suckage on their teats, the cow either dies or gets Really, Really Pissed.

      You want a revolution? A real one? NO, you *DON'T* -- you want the system to stay working because the alternative is just unimaginable. That's why you've got the "Preppers" in the US, because they think they CAN imagine it.

    12. Re:Tactical Move by Anonymous Coward · · Score: 0

      But the thing that all us little people need to remember here is that every pound, euro or dollar in tax that Apple "avoids", well that's a pound, euro or dollar that we have to find. When companies don't pull their weight, tax-wise, the private individuals are the ones who get stung.

      In this world of yours is there max cap of collected taxes? Where does the idea that individuals would pay less tax because a company paid more come from? Letting Apple pay more taxes is a terrible idea because it lets the governments think they deserve to operate with even more money, when they should have less.

    13. Re:Tactical Move by ytene · · Score: 1

      OK, good question.

      The context I was trying to get with that was as follows:

      Imagine that the UK government spending is £750 Billion per year. So to "balance the books" - i.e. operate the national budget without running a deficit - the UK needs to generate £750 Billion of income in the form of taxes.

      So suppose, just for our hypothetical conversation, that businesses operating in the UK contribute £400 Billion and private individuals contribute £350 Billion. Now imagine that of that £400 Billion, approximately £100 Billion is profits earned by foreign-owned companies, like Amazon, Apple, eBay, Microsoft, McDonalds, Starbucks, etc. Using these "tax loopholes", these non-UK companies "move" their profits to other jurisdictions where there is little or no corporation tax and then declare it. So instead of the UK collecting £400 Billion in taxes, they only collect £300 Billion.

      With me so far? Because what happens next is where it hurts. The UK still needs £750 Billion in taxes to cover expenditure. So, with only £300 Billion now coming from business taxation, the Treasury has to find additional money from somewhere. Guess where? Private individuals - individual tax-payers. So the tax burden for private people goes up from £350 Billion to £450 Billion.

      It gets worse. Because non-UK companies [and this is the same for non-French, non-German, non-Dutch, non-Spanish, non-Italian, etc, etc] companies are paying such a small amount in tax, their operational costs are lower. As a result of this, they can reduce the cost of their products - in the markets they serve - without actually losing money. So now, if you are a UK-owned, UK-run and UK-taxed company [non-UK readers won't have heard of "Argos", but they are a bit like a tiny version of Amazon, a company which grew up from catalogue and mail-order sales], you can sell the same products as Amazon, but you end up having to charge more in order to meet your tax bill.

      So the deal that allows "foreign" companies to pay no tax doesn't just hurt private EU tax-payers, it also destroys competitor EU businesses, by pricing them out of their own marketplace. How could it be that, i.e. Amazon, can sell me the same product, shipped from Germany, *overnight*, for less than it costs a UK competitor to ship me the exact same thing with a 3-5 day delivery lead time? Answer: it's all done by not paying taxes in the UK, then using that as a margin to undercut local competition.

      The current tax system is destroying entire countries...

    14. Re:Tactical Move by PPH · · Score: 1

      Apple evaded taxes by declaring them in an imaginary company that was not based in any country on earth.

      Of course you have the corporate parents articles of incorporation in front of you to back this statement up. Or are you just confusing the non existence of a fixed location with no requirement to declare one. Because that's the way many countries tax and incorporation laws are set up. There is no requirement to identify the beneficial owner of a company. And that would of course include its location.

      --
      Have gnu, will travel.
    15. Re:Tactical Move by Anonymous Coward · · Score: 0

      Is no candidate proposing to simply start taxing profits held overseas? Less whatever tax they paid overseas of course.

      That is already the law in the US, truly identical right down to reducing tax burden based on taxes paid elsewhere.

      The double-Irish loophole is so popular because it was one of the few viable ways to avoid the law.

    16. Re:Tactical Move by drinkypoo · · Score: 1

      But unfortunately the USA has plenty of tax havens in several states, Nevada, Delaware, South Dakota, Wyoming as a few of the most known

      The writing is on the wall for them, too; they're a bit trickier because they can shout "states' rights" and delay things for a time but their days are numbered as well.

      --
      "You're right," Fisheye says. "I should have set it on 'whip' or 'chop.'"
    17. Re:Tactical Move by smallfries · · Score: 1

      Which countries allow the incorporation of companies that operate so that they are not taxed by a country? (specifically not avoiding dual taxation by paying taxes to a different country).

      --
      Slashdot: where don knuth is an idiot because he cant grasp the awesome power of php
    18. Re:Tactical Move by PPH · · Score: 1

      Ireland, for one.

      The United States is a big one. As long as you pay taxes here (which can be very low or non-existent), the USA is one of the biggest tax shelters in the world.

      --
      Have gnu, will travel.
    19. Re:Tactical Move by smallfries · · Score: 1

      so no then. Ireland does not. You state the US does not. So who does?

      --
      Slashdot: where don knuth is an idiot because he cant grasp the awesome power of php
  18. Re:rats fleeing the sinking ship by Anonymous Coward · · Score: 1

    Profit shifting

  19. Re:rats fleeing the sinking ship by rwyoder · · Score: 2, Insightful

    most likely a result of there tax haven (Ireland) no longer being as safe a place as they thought to hide there stolen billions.

    You keep using that word. I do not think it means what you think it means.

  20. Re: rats fleeing the sinking ship by Anonymous Coward · · Score: 0

    If anything it's the the government that steals through taxation.

  21. Re:rats fleeing the sinking ship by ComputerSlicer23 · · Score: 1

    The gov't printed the money, clearly they're just trying to collect their property...

  22. U.S. Corporations need to pay U.S. taxes. by bjwest · · Score: 2

    Regardless of where the income is generated, U.S. corporations need to pay U.S. taxes the same as any U.S. citizen. Calculate the tax after all (foreign) wages, expenses and taxes are subtracted. No more of this slight of hand bullshit, pay your fucking taxes or move your corporation. Hell, most have already moved the majority of their workforce, the rest of the U.S. based employees are executives and their staff.

    --

    --- Keep the choice with the user..
    1. Re:U.S. Corporations need to pay U.S. taxes. by Rakshasa+Taisab · · Score: 5, Insightful

      One of the most fucked up parts of being an U.S. citizen is that even if you work, live, breath on foreign soil you still need to report everything to the US tax office.

      Basically the only country in the world that will keep fucking you over even after you try to leave it behind for ever. Glad I'm not a 'citizen'.

      --
      - These characters were randomly selected.
    2. Re:U.S. Corporations need to pay U.S. taxes. by Anonymous Coward · · Score: 0

      The US is the only country that does this. Everyone else understands you pay taxes where you earned it.

      Only a fucking moron would insist that the IRS become adept at finding all sources of income around the world.

    3. Re:U.S. Corporations need to pay U.S. taxes. by houghi · · Score: 1

      There are thousands that are coming to Europe as well. Your point being? And most of the time denouncing a nationality is not even worth the trouble. You just stop picking up your passport.
      I know plenty of people who never denounced their nationality, yet have no interest in having it. Why bother if doing nothing is easier then taking action and cheaper as well.

      --
      Don't fight for your country, if your country does not fight for you.
    4. Re:U.S. Corporations need to pay U.S. taxes. by ledow · · Score: 3, Insightful

      Demonstrating, yet again, that the US only cares about its own, and nothing and nobody else. Such an insular country and people, obsessed with money (you mention rich foreigners, nowhere do you discuss any other aspect they may have).

      And who the hell wants a baby that's going to be taxed when it's born to foreign parents, lived its life on foreign soil, and never knew the US at all? That's baby tourism. What you're talking about before that is actually immigration, which is universal (they are 30,000 people in France at the moment trying to get to the UK, the demand has little to do with it being a benefit to the country they are trying to get to).

      Those people coming in to the US, they have citizenship of other countries. Those countries - without exception - do not tax them while they spend their lives in the US. The US tax people who have left the US, however. Until their denounce their citizenships entirely.

      This means that your students never stray outside your borders. They can't. They can't afford to be taxed by others and by the US at the same time.

      This means that your professors and other academics cannot travel and work outside the US. Not without being penalised much more than their peers in other countries, or denouncing their citizenship - which is a one-way street. If they want to go work on a project on an Australian telescope, they are double-taxed all they time they do, unless they decide to leave the US permanently and live and work in the other hundreds of countries the world over that don't do that to them.

      What you've got is a system that keeps all the worst - the "baby tourists", the illegal immigrants, the jobless and the stupid - and punishes anyone who wants to see the world, work internationally, or do any kind of international collaboration. It's called brain-drain and double-taxation is the PERFECT way to cause it.

      And the problem is that it's a self-reinforcing problem. The more stupid people that stay and the more clever, innovative, and internationally-demanded that leave, the more people left behind think it's a "good thing", and you end up with a Donald Trump situation where the whole world are looking at you thinking "You fucking idiots" and yet half your country are cheering him on because everyone with a brain already left or will be forced out.

      You're not alone - Brexit is going to have roughly the same effect unless they can guarantee rights for EU people already working here, but we're not stupid enough to tax them for even trying to go and work with the rest of the world

      My girlfriend is a Dr (which means something over here), and Italian - Italy PAID HER to come to the UK. They PAID HER to study here. They do not tax her while she's not at home. The UK PAY HER over the odds to come here, as only a handful of people can do her job, which is taxed in the UK only.

      She works in a NHS hospital diagnosing genetic diseases and cancers.

      Her friends, almost to a person, are all EU, or foreign citizens. Mexico, Spain, France, Italy, Romania, Poland, Russia. They ALL PAID their people to come to the UK, get educations, make the big bucks and send money home. Because they know that nothing beats international experience, recognition, education and talent. They don't tax anything while they're not on their home soil.

      Those people are going to retire back to the country, or they are going to qualify quickly and bring back foreign expertise, techniques, standards and better ways of doing things - for free. They are going to earn bigger money than their home countries could afford (my gf literally laughs at what Italy will pay her to do the same job over there) and send it home. And they will have well-rounded, collaborative careers.

      The US are basically fining people for wanting to go to the rest of the world. You can't study abroad. You can't work abroad. Even places like China and Korea don't stop that for their academics. Hell, you get less holidays than just about every other country in the

    5. Re:U.S. Corporations need to pay U.S. taxes. by bjwest · · Score: 1

      If you want to leave it behind forever all you have to do is give up your citizenship. Same with corporations. If you don't want to pay U.S. taxes, give up your U.S. corporation status.

      --

      --- Keep the choice with the user..
    6. Re:U.S. Corporations need to pay U.S. taxes. by Anonymous Coward · · Score: 0

      Not the only country. I'd guess the members of those double-taxation avoidance agreements are mostly requiring the reports for both sides, while some countries require reporting all income, capital gains, pensions, social security payments and benefits, lottery winnings, gifts of certain sizes and all the other little things..

    7. Re:U.S. Corporations need to pay U.S. taxes. by thegarbz · · Score: 2

      Basically the only country in the world that will keep fucking you over even after you try to leave it behind for ever. Glad I'm not a 'citizen'.

      Except for Australia, India, and the many members of the EU, which incidentally if any have double taxation agreements with any of the former countries you're also screwed.

      I.e. Australia as an agreement for double taxation with the Netherlands. So if you're Dutch and live in Australia you need to report your income in the Netherlands. If you live in Canada you do not. Things are much more complicated than just the USA, though looking through the rules I believe the USA has the most onerous requirements for being a foreign resident.

    8. Re:U.S. Corporations need to pay U.S. taxes. by Anonymous Coward · · Score: 0

      Not quite.

      For US citizens living abroad, you do have to file and report your earnings every year, but only a very small percentage of expats pay additional taxes back to the US.

      for 2015, the first $100,800 earned are excluded, and you pay 0 US taxes on that regardless of foreign residency. So for most people (and specifically almost any student) you will not have to pay additional taxes. For money earned above that, it depends which country you are a resident in, and how much tax you pay. If the country you are a resident has a tax treaty (https://www.irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z) with the US, you only pay taxes if you were taxed at a lower rate than you would have been taxed for federal income. And US federal taxes are already lower than many if not most of those countries.

      In addition to that, for many of the countries they have agreements in place to take into account the equivalent of social security. As an example, I live and work in Poland currently each year I pay into Poland's social plan (ZUS) counts as if I paid Social security and vice versa, so If I retire in the US, I will receive social security benefits for the number of years I paid into the US, as well as the number of years I paid into Poland. Or if I retire in Poland, they will treat the number of years I had already paid into the US as if I had paid ZUS.

      Are their cases where US citizens abroad get screwed on this, yes. But not many.

      As for the holiday thing, that's highly variable (usually between 8 - 13, as some companies don't recognize all federal holidays, and many companies give days off that are not federal holidays, Friday after Thanksgiving, and good Friday before Easter are one's that I've had at various companies for example).

      In addition, employees generally get multiple types of 100% paid days off. There's usually vacation days (normally 10, 15, or 20 but this varies by company, seniority, and what you personally negotiated (if you are not part of a union). then you have personal days. these are usually between 2 to 5 per year (which can be taken whenever on demand without notice). And then their are Sick days (100% salary paid by the company, which is different than . Usually around 5 per year, but at many companies these will roll over and accumulate if you don't use them up to a certain point (again varies by company). So having a total of 20-30 100% paid days off for a full time employee in the US is not unusual. (If I were still in the US at my company I would have 33 guaranteed days off, which is more than I get in Poland).

    9. Re:U.S. Corporations need to pay U.S. taxes. by geekmux · · Score: 1

      If you want to leave it behind forever all you have to do is give up your citizenship.

      So, in other words, even if you're born a natural US citizen and choose to work in another country, you continue to be taxed on your Freedom to return to the US at any time.

      Freedom. Who knew it was such an oxymoron...

    10. Re:U.S. Corporations need to pay U.S. taxes. by pnutjam · · Score: 1

      Ex-pats always go running to the Embassy whenever they get in trouble with the local govt. The US should collect taxes, they provide services, mostly threats and intimidation.

    11. Re:U.S. Corporations need to pay U.S. taxes. by NotAPK · · Score: 2

      The difference is that US citizenship carries certain obligations. One such obligation is a requirement to file taxes in the US, irrespective of where you live. The US is only one of two countries with this requirement, the other is Eritrea.

      So yes, I can see why some US citizens may wish to denounce their citizenship. But as you say, citizens of most other countries certainly wouldn't bother.

      There was another poster here saying that they thought people should only hold citizenship of one country. I disagree with that statement. Though I'm probably in the minority: I don't believe anyone should have passports and that all borders should be open and free to cross. Everything (gears of society) should be based on where you physically are at the time, (no residency or citizenship requirements) so revenue is all earned through sales taxes, consumption taxes, land taxes and income taxes, and similar. Corporate taxes should be based on where the corporation is trading. If the company trades in a country then it must have an office/subsidiary in that country and it is against that office that the taxes are levied. There would be an exception for small (# employees, $ traded, etc...) companies that trade internationally. Of course some refinement is required.

      A nice result of this outlook is that a society should earn enough from taxation based on its residents to provide all the services required. That revenue should scale with volume. The real benefit is that anyone should be able to walk into any hospital and receive treatment anywhere. Of course there will be cross-over as people out of jurisdiction receive services away from home, but the grown up response is to realise that on the whole it would all cancel out.

    12. Re:U.S. Corporations need to pay U.S. taxes. by NotAPK · · Score: 2

      Thank you for the extra information. I agree entirely with the parent poster's spirit, though they did make a few mistakes over the double-taxation which you helpfully corrected.

      However, your information on holidays while correct, still supports the parent poster's message: the US does not grant enough holiday time to its citizens to visit the world. As someone who has lived and worked in Australia, the USA, Canada, and the UK, I know that the USA was the absolute worst when it came to pay, benefits, and working conditions. And this was while filling a mixture of STEM project management and engineering positions. I could only pity those with less education and really feel for everyone in the USA struggling to get by.

    13. Re:U.S. Corporations need to pay U.S. taxes. by Anonymous Coward · · Score: 0

      Freedom isn't free. Freedom costs a $1.05.

    14. Re:U.S. Corporations need to pay U.S. taxes. by Anonymous Coward · · Score: 0

      Are you aware of the foreign tax credit?

    15. Re:U.S. Corporations need to pay U.S. taxes. by chasm22 · · Score: 1

      You're an idiot. Your use of a broad brush to portray every American as ' THE FUCKING UGLY AMERICAN' is more a painting of you then one of us.

      And you base almost everything you say on your complete misunderstanding of the US Tax Code. Read this. https://www.irs.gov/pub/irs-pd...

      You talk about brain drain and wind up with another mess on your hands. First you say the tax code prohibits Americans from working or studying abroad. OK, wrong but just for a minute I'll go along. Then you describe this same situation as the perfect scenario for brain drain to occur. Maybe you'd care to explain how a country that doesn't allow citizens to work or travel abroad goes on to become one that suffers brain drain. I know what's coming next. Please include some cites to prove that students who study abroad are smarter than those who don't. Or more inventive. Or entrepreneurial. Or more well rounded. Yeah, I need some cites. Only because you made such a debacle of your original theory about the US going to shit.

      Your ideas are cleverly ignorant. You act as if a scientist would automatically become better if he meant a few scientists from other countries.
      Hmm? You do have some facts to back up your fiction, right?

      And tell me, what does a country which sends it students to another country to learn and earn suffer from if it isn't brain drain?

      And then do us a favor and shut the fuck up. You just did Brexit. There is a reason why there are 30,000 people in France waiting to get into the UK. The word that comes to mind to describe the situation is bigotry.

      Say what you want about Trump. The facts are that he has never enjoyed a poll where his approval rating was anywhere near as high as his disapproval rating. You rant about Trump and seem to forget that we just elected a black person twice and are on track to elect the first female. No, she won't be like Thatcher. Thank God.

      Next time, before you rant about the US being insular,take a good look at your country first. Maybe you should first ask yourself why your country is still 87% white. Our fucking whitest neighborhoods aren't that white! You want insular? Yeah I've got some. In the UK, apparently being white isn't enough. You have to be the right kind of white. As in non-Polish white. But maybe that's just the boys being pranky. Just trying to keep things organized. Well, maybe a little insular. And a little racist.

      No a better example of a nation/kingdom being insular would be the 'classic' example. Brexit. Not much to add to that is there? Calling the US insular in its attitudes is lau
      ghable in contrast to actually voting on the issue.

    16. Re:U.S. Corporations need to pay U.S. taxes. by Anonymous Coward · · Score: 0

      While I won't argue that all is well in the US, some of your comments seem over the top and unsupportable. Firstly, where is this brain drain? Surely you could point to the mass evacuation from the US of the educated. Only you can't because even now the situation is the reverse. You did point out one instance of brain drain from a country whose policy you would apparently rate higher than the US in the form of your girlfriend. The US pays people to work abroad in certain roles and I have known a few. President Clinton himself was paid to study in the UK when he was a student so I'm not sure where you get the idea that such things do not happen for US students. I would likely agree with you about many policies involving the subjects you discuss but you misrepresent the US position and seem to fabricate some brain drain scenario whole scale.

      One more thing....Berlusconi.

  23. what a dispicable company by Anonymous Coward · · Score: 1

    and every word that comes out of tim cooks mouth is a toxic hellstew of lies

  24. Lower Corporate Tax Rate by nehumanuscrede · · Score: 4, Interesting

    I would be all for lowering their taxes, on one condition.

    American workers only within the US.

    You want the tax breaks ? You quit going the H1B route cheating the US workforce out of a job.

    You hire foreign labor ? Your tax rate will increase to compensate. Pretty simple. Do the math, set the rates to make hiring US workers a financial win for the company. Price of doing business in the US I'm afraid.

    Don't like it ? Move your company to India or Ireland or wherever you want. See how well you do when you're denied access to the US market.

    Those that are gaming the system can just gtfo or deal with the tax man.

    1. Re:Lower Corporate Tax Rate by Anonymous Coward · · Score: 0

      I still think Apple should pay their European tax bill. I'm a right-wing patriot and all, but fuck Apple. They've conspired against American workers (anti-poaching agreements); claim to stand for principles, yet make their products in China (bad labor and environmental records); create the most controlling and expensive products (no audio jack, one USB-C port on a MacBook, iTunes, etc.).

      If they want to act like a borderless transnational, then let's treat them as one. No special favors.

      For any country: if they don't pay their taxes, their products are blocked from entering the country. Their executive will be bared from entering as well. Assets will be seized.

      Just desserts.

    2. Re:Lower Corporate Tax Rate by Anonymous Coward · · Score: 0

      I agree with all I see here but I don't see any global company falling on their sword and thusly bleeding ca$h to benefit the US workforce. Kudos to you and your vision of a tax law that supports their U.S. based employees and maybe makes its reasonable to move production to a CONUS location.

      In celebration of this pipe dream I'm gonna go look up "pigs fly" on YouTube.. I'm sure there is video that is appropriate.

      Peace out.

    3. Re:Lower Corporate Tax Rate by aliquis · · Score: 1

      Do it the Swedish way:

      PAY to have the taxes, the company and any money to buy any of the services or products moved to say Somalia instead.
      That or simple move everyone in Somalia to the US.

    4. Re:Lower Corporate Tax Rate by Tesen · · Score: 1

      I agree with all I see here but I don't see any global company falling on their sword and thusly bleeding ca$h to benefit the US workforce. Kudos to you and your vision of a tax law that supports their U.S. based employees and maybe makes its reasonable to move production to a CONUS location.

      In celebration of this pipe dream I'm gonna go look up "pigs fly" on YouTube.. I'm sure there is video that is appropriate.

      Peace out.

      "I'm gonna go look up "pigs fly" on YouTube.." -- yeah because things change by throwing up your hands and walking away in disgust... uhhuh.

    5. Re:Lower Corporate Tax Rate by Anonymous Coward · · Score: 0

      Thank god dumbasses like you have zero input on economic issues then, hey?

  25. Sounds like a negotation tactic by JoeyRox · · Score: 1

    Timmy has no intention of suddenly paying a much higher corporate tax rate by repatriating funds. He's only looking for leverage against his European bureaucrat opponents by recruiting eager EU members like Ireland to fight for him to preserve what little he contributes to their economies.

  26. Shouldn't Be Possible by Anonymous Coward · · Score: 0

    It should be illegal to move income like that.

  27. Nothing at all to do with what just happened...... by Anonymous Coward · · Score: 0

    And.......

    This has absolutely nothing to do with what recently happened in Ireland where it was found that Ireland had violated European law and charging Apple a 1% to 0.005% profit rate for the past decade all while funneling their US and the bulk of their European profits through it and now has the European governments ordering them to pay back at least 13 BILLION dollars in back taxes that it had managed to evade on.

    This change has nothing to do with that..... Nope, just trying to what the right thing.

  28. At what cost? by XSportSeeker · · Score: 0

    Just remember folks, if Apple repatriates a big part of the business that is currently on Ireland, this means:

    - Ireland will have huge losses - jobs, tax revenue, etc;
    - Apple product prices could increase even more, as taxes increases and the transition will probably not be cheap. The money to cover such moves always comes from somewhere;
    - Sour relations with EU will probably have consequences as well;

    I mean, if it really happens, it initially sounds great for the US. Big tax influx, jobs and all, though I'm not quite sure the next president will really make good use of that. :P But when such a huge ammount of money suddently moves from one country to another, the consequences tends to be extreme on both sides.

    In a way, I guess it's kinda fair... tax heaven countries and states are overall damaging to the company's country/state of origin. It ultimately means that huge companies making huge profits return less for the community they have business at.
    But changes on that scale are still worrying.

    1. Re:At what cost? by ledow · · Score: 1

      Given that most of the other EU countries are seeing precisely zip of Apple's taxes anyway (because Ireland are charging them at a rate of 0.005%), every country won't be sorry to see them go either.

      Literally, they are doing masses of business in the EU and paying "less tax than a sausage stall".

      If they are a US company taxing themselves in the US, then we have taxes that capture that when they sell product in the EU. If they are a EU company taxing themselves in the EU, then we see direct taxes from them. When they are playing one EU country off against the entire rest of the world, nobody sees any tax, but the country that allows them to do it get a few thousand jobs for the price.

      What we have is a country in need of jobs willing to sacrifice tax on the sly, until it got caught, to keep them. Meanwhile, everybody else is pissed that Apple aren't paying a penny to the UK, Germany, France, etc. while making BILLIONS from customers in those countries. And the EU is just as big a market at the US.

      This has nothing to do with WHERE they are taxed. It's to do with what tax they are paying. And they are paying fuck all. And they moved out of the US specifically so they COULD pay fuck-all, and now that's caught up with them and there's no safe-haven left in Europe, where they continue to pay fuck-all.

      And now they've twigged that running a complicated tax evasion scheme - no matter how "legal" it appeared at first, but certainly isn't now the EU commission has caught wind of it - to pay the same taxes as they would have to pay in the US is actually going to cost them more.

      So they're "graciously" agreeing to go back to the US, spin it as positive PR, and pay ORDERS OF MAGNITUDE more tax, the same as everybody else, for once in their life and abandon their complicated tax evasion and foreign offices designed to do nothing more than evade tax.

      In other words: "Shit, they noticed, and even Ireland can't pretend they didn't know they were giving us billions in free money for no reason, we'll have to start paying "real" tax from now on... May as well do that from home."

    2. Re:At what cost? by dbIII · · Score: 1

      - Ireland will have huge losses - jobs, tax revenue, etc;

      Not as such. The Irish government has been looking the other way with taxes and the jobs are only enough to retain a "paper presence" as the headquarters instead of actually being the real headquarters. Even if the "6000 jobs" is real (which I very much doubt) there are layoffs bigger than that all the time that hardly make the papers.

      Apple product prices could increase even more

      Profits have been staggering, so a reduction isn't going to kill Apple while attempting to retain staggering profits while competing with Samsung etc selling for less may hurt Apple a lot. I doubt the product prices will increase much. Would you buy the latest iPhone if the latest Galaxy or whatever was less than half the price?

    3. Re:At what cost? by dbIII · · Score: 1

      What we have is a country in need of jobs willing to sacrifice tax on the sly, until it got caught, to keep them

      While that is the excuse there are hardly any jobs at stake - what to look for is a money trail into specific pockets.
      Pretty fucking sordid isn't it?

    4. Re:At what cost? by khallow · · Score: 1

      What do you think Apple does with that Irish money? Throw it into a very large hole in the ground? It gets invested locally and generates revenue locally. That leads to more jobs locally.

    5. Re:At what cost? by Anonymous Coward · · Score: 0

      Stashes it in a secret account so no one can tax it while looking for the next tax scam to move it into.

    6. Re:At what cost? by dbIII · · Score: 1

      How incredibly naive. That money does not stay in Ireland.
      The money "invested locally" is from that 0.005% tax rate that they agreed to pay and whatever kickbacks had to be paid to get that 0.005% tax rate.

    7. Re:At what cost? by khallow · · Score: 1

      Ireland gets a lot more of it than if it found its way back to the States. Keep in mind that those kickbacks have to include the Irish voter too.

    8. Re:At what cost? by dbIII · · Score: 1

      Keep in mind that those kickbacks have to include the Irish voter too

      Do you really think that's the way it happened?

      Ireland gets a lot more of it than if it found its way back to the States

      No, that money did all "find it's way back the the States" apart from a very tiny percentage.


      I suggest you read something on this topic instead of just making incredibly naive guesses which you have decided to share with us for some strange reason.

    9. Re:At what cost? by khallow · · Score: 1

      No, that money did all "find it's way back the the States" apart from a very tiny percentage.

      The current story indicates otherwise since otherwise there wouldn't be anything to repatriate. I guess I must prepare myself for yet more content-free assertions about Apple's accounting magic.

    10. Re:At what cost? by dbIII · · Score: 1

      more content-free assertions

      Instead of continuing to make those I suggest you read something on this topic instead of just making incredibly naive guesses which you have decided to share with us for some strange reason.
      The story starts in 1991 in County Cork with Apple making threats to a small local government.

    11. Re:At what cost? by khallow · · Score: 1

      That's a great idea. Why don't you do that and get back to us in a few months?

    12. Re:At what cost? by dbIII · · Score: 1

      That stupid act is so cute. Do you do balloon animals too Pogo?

  29. Re:rats fleeing the sinking ship by bloodhawk · · Score: 0

    it means exactly as it was meant to mean. They made an illegal deal with the Irish government to act as a tax haven to shelter their earnings from other countries. You can call it profit shifting, tax minimisation or whatever the hell you want, but it has been declared illegal finally and I call it theft.

  30. Re:Not familiar with how Clintons work, are you? by Anonymous Coward · · Score: 0

    Didn't help them out when they supported Obama, on the other hand Bush Jr did.

  31. Re:Trump 2016! by nospam007 · · Score: 4, Funny

    "Make America great again! Lower takes and make other countries pay for our walls!"

    Since you obviously don't even know how 'taxes' is spelled it raises the question:

    Is that you, Donald?

  32. Re:rats fleeing the sinking ship by Anonymous Coward · · Score: 0

    by moving profits to Ireland they are in effect stealing tax revenue from other countries in a shell game that Ireland has been complicit in. Ireland gets jobs and apple gets a safe haven to hide profits and avoid tax.

  33. the cow goes 'moooo'.. by Anonymous Coward · · Score: 0

    the apple ceo goes 'waaaaahhhhhh'

    now is not the time to throw a tantrum, now is the time to man the fuck up and pay your fucking taxes.

  34. Re:rats fleeing the sinking ship by nospam007 · · Score: 4, Insightful

    "it means exactly as it was meant to mean. They made an illegal deal with the Irish government to act as a tax haven to shelter their earnings from other countries. You can call it profit shifting, tax minimisation or whatever the hell you want, but it has been declared illegal finally and I call it theft."

    Not at all, it has been considered as an illegal subsidy/gift _from_ Ireland to Apple and the Irish are now 'forced' to ask for that 'gift' back, just like other countries before them.

  35. Proit by ledow · · Score: 5, Interesting

    It's easy to make more profit than your competitors when you're aren't paying any tax, in any country that you operate in.

    Strangely bad for PR when it gets on the news, though. And strangely ends up changing from a hush-hush golf-and-a-posh-meal secret deal with the local ministers to laws being changed to prevent it happening when it does make the news.

    Starbucks found that out in the UK.

    So, technically, Apple don't make 40% of the profits in the Silicon Valley. Because those profits aren't properly taxed. And they aren't registered as profit in Silicon Valley at all. They are registered as profit only in Ireland. Which was charging them basically 0% tax. They are the LEAST profitable company in Silicon Valley, or else the US taxman would have had their share a long time ago.

    But they are in fact the most profitable in Ireland, while also being the least taxed. Strange that.

    I could earn twice what I do if I didn't have to pay tax.

    And I could make any company outstrip all its competitors if it didn't have to pay tax (get company, make no changes, stop paying tax, bang, you just doubled your profit most likely, and can lower prices or buy suppliers to put your competitors out of the market).

    I'm much more interested in an article entitled "Who pays the most tax in Silicon Valley?"

    1. Re:Proit by redback · · Score: 0

      they dont put their US profits through ireland, only EU stuff

    2. Re:Proit by FlyHelicopters · · Score: 1

      I could earn twice what I do if I didn't have to pay tax.

      If you're paying 50% tax, you're a complete moron who has some REALLY bad tax advice...

    3. Re:Proit by Anonymous Coward · · Score: 0

      Depends on the country, right?

      I used to pay 54% effective "tax" rate (tax + mandatory social security) with little to no room of optimization.
      (I could get tax deductions for paying into a pension fund, but I was young and needed the cash more. And basically that was it).

    4. Re:Proit by Anonymous Coward · · Score: 0

      Apple has become a monster that needs to be slayed or at least leashed and corralled, Their position as a direct competitor to Microsoft's monopoly is weakened by the rise of alternate operating systems and applications in the form of BSD and more notably by the GNU/Linux distributions. By the way, aside from capital investments for equipment, buildings, and associated items and salaries, there should be no deductions w.r.t. taxation. Each employee laid-off should automatically trigger a one-time 100,000.00 tax charge and firing an employee cannot be used to evade it.

    5. Re:Proit by Anonymous Coward · · Score: 0

      I could earn twice what I do if I didn't have to pay tax.

      If you're paying 50% tax, you're a complete moron who has some REALLY bad tax advice...

      You are probably paying 50% too. You're a "complete moron" for not noticing all the taxes you pay, most of which an accountant can't touch. Income tax, SS, property tax, capital gains, sales tax, inheritance, the various taxes on your phone and utility bills, built in taxes from products like gasoline, alcohol, insurance, on and on it goes. Add it up.

    6. Re:Proit by ledow · · Score: 1

      From http://www.forbes.com/sites/le...

      "Apple set up some Irish subsidiaries a mere four years after it was founded. Foreign sales, which account for 60% of Appleâ(TM)s profits, are routed through these Irish subsidiaries and taxed nowhere. How is this possible, when the intellectual property that supports the value of Appleâ(TM)s products is in the United States?

      Apple has an Irish holding company with no operations or employees at the top of its foreign operations. This company also serves as a group finance company. Apple Inc., the U.S. parent of the whole group, pays U.S. tax on the investment earnings of this company. Otherwise, the holding company pays no tax to any government, and has not paid tax for five years. It claims tax residence nowhere."

  36. Re:rats fleeing the sinking ship by Anonymous Coward · · Score: 0

    Not at all, it has been considered as an illegal subsidy/gift _from_ Ireland to Apple and the Irish are now 'forced' to ask for that 'gift' back, just like other countries before them.

    Not at all yourself. All tax codes around the world categorically state that profits must be booked where they are earned. That makes profit shifting/transfer pricing illegal but because it's difficult to prove many companies, particularly those dealing in "intellectual property" where it's basically impossible to prove, do it anyway.

  37. Just a guess... by HanzoSpam · · Score: 1

    It looks like Apple is assuming Trump will be in office by next year. I doubt that they have any intention of importing their money just to get it confiscated.

    --

    Progressivism: Parasites helping parasites to help themselves - to other people's stuff.
    1. Re:Just a guess... by iggymanz · · Score: 1

      you people who think the Clinton's aren't mega-corporate bitches too are amusing

    2. Re:Just a guess... by Opportunist · · Score: 2

      Yeah, 'cause Hillary is the big evil socialist-marxist-tax-them-fuckers-out-the-wazoo bitch.

      She's a bitch all right. But the only marxist in this race is Trump. And he's more of the Groucho kind.

      --
      We used to have a Bill of Rights. Now, with the rights gone, all we have left is the bill.
  38. With all the US Loopholes it's no wonder by Anonymous Coward · · Score: 0

    On the books, US has a somewhat high corporate tax.. but with so many loopholes, the ones with enough lawyers and accountants pay much much less. Doubtless this is Apple's strategy once they repatriate, so while they'll pay somewhat more than Ireland's ~0% tax, it'll still be way, waaaaay less than they should be. And they'll whine publicly all the way, while they make a big PR song and dance about "coming home" and "doing the right thing".

    Barring Ireland, if they could legally get a rate lower than US+loopholes they'd be talking about moving to wherever that would be.

  39. So what... by footNipple · · Score: 1

    They bring the cash back to the US, deposit close to 50% into the US general treasury and spend the remainder on foreign parts and labor. Next story.

  40. Time for a very old joke by dbIII · · Score: 1

    C: Sure I know how to spell Taxes - my cousin lives in Taxes.
    G: No - dollars, dollars!
    C: Atsa right - he lives in Dollars Taxes.

    1. Re:Time for a very old joke by Anonymous Coward · · Score: 0

      I believe that should have been G: No - Dollars, Taxes.

    2. Re:Time for a very old joke by dbIII · · Score: 1

      OK then - here is the real thing, from the internet instead of dusty memory:

      Prosecutor: Something must be done! War would mean a prohibitive increase in our taxes.
      Chicolini: Hey, I got an uncle lives in Taxes.
      Prosecutor: No, I'm talking about taxes - money, dollars!
      Chicolini: Dollars! There's-a where my uncle lives! Dollars, Taxes!

    3. Re:Time for a very old joke by Anonymous Coward · · Score: 0

      Don't mess with Taxes!

  41. calling someone naive by publiclurker · · Score: 1

    and then linking to breitbart shows both an absurd level of ignorance, and a desire for ridicule.

  42. Re:rats fleeing the sinking ship by FlyHelicopters · · Score: 1

    it means exactly as it was meant to mean

    Then you STILL don't know what it means...

    I'd explain it to you, but you likely aren't listening, so what's the point?

  43. Re:Trump 2016! by Anonymous Coward · · Score: 0

    Make Apple Great Again!

  44. Comment removed by account_deleted · · Score: 1

    Comment removed based on user account deletion

  45. Yeah, nah by Anonymous Coward · · Score: 0

    I say screw'em. Classify this behavior as what it is, tax evasion. Arrest, try and throw each of these tax avoiding asshole CEO's into jail. Job done.

  46. taxes and human rights by siamesevodka · · Score: 0

    What I don't understand about all of this is Congress is mad at the EU for wanting to tax the enormous profits of a multinational whose Human rights record is not very good.I understand Ireland wanting to set itself up as a tax haven for Apple. But that violates the rights of the EU. Congress should be mad at Apple for parking it's money offshore. I just read on here the other day Apple increased its profits by having the company in China who makes their products cut pay and increase hours on the workers. Everybody thinks poor Apple is the victim in all this. I think everybody is the victim of poor Apple. We have been denied any tax on their profits, their Human rights record stinks, and their products are overpriced. I'm not knocking the quality or performance, just the price.Price they put on Humans and the price they put on the USA for what they are doing. I for one don't drink the Apple juice. I think if they were boycotted for the business practice it would go a long way towards changing their culture. Probably won't happen though, cause nobody cares.

  47. How interesting.... by erp_consultant · · Score: 1

    Cook is saying that Apple will repatriate profits...next year. As in after Obama is out of office. Clearly, Apple has not been able to negotiate an agreement with the Obama administration that they can live with. By saying next year Cook is basically saying that he has given up on this administration. Trump has already come out publicly against the EU decision.

    Interestingly the Obama administration is also against the EU decision. Why? I can think of two possible reasons:

    1) They would rather get their own grubby hands on the money...or....
    2) If Apple ends up paying the EU then that money will pass through as a US tax credit for Apple. Dollar for dollar. Which means that basically the US taxpayer will end up being on the hook for all those billions of dollars.

    What is interesting to note is that this whole thing is fault of the federal government. They wrote the laws that Apple is using to their advantage. Government accepted the bribes...err...political campaign contributions that allowed business to influence the laws to their liking.

    1. Re:How interesting.... by EvilAlphonso · · Score: 2

      The US government may possibly looking for the $44bn of US tax money that Apple funneled through Apple Operations International (Incorporated in Ireland, operated from the US, paying tax nowhere), according to a US senate inquiry in 2013.

    2. Re:How interesting.... by Anonymous Coward · · Score: 0
      The US taxpayer won't be on the hook for anything. That money is never coming back at standard rates. It's a fantasy to assume it is. If they don't get some kind of special deal, they will just leave it outside America and bump it on to the next tax haven.

      The US government doesn't pay for much of anything with the taxes it collects, it borrows most of its money anyway, at just about zero interest.

  48. You forgot Eritrea by sciengin · · Score: 1

    Eritrea is the only other country that taxes the revenue of its citizen worldwide.
    You might know Eritrea as being extremely high on the scale of respecting human rights. /s

  49. Bring back? by Anonymous Coward · · Score: 0

    Was the money ever in the U.S.?

    If Apple "brings money back", what impact would that have on the bonds market?

    Why bother bringing it to the states? What overall positive impact does it have for anyone at all?

    What will the national impact be on Ireland and others? I'd imagine that this could quite severely negatively disrupt the world economy.

    I suppose that is what they want people to worry about.

  50. Translation by Opportunist · · Score: 1

    We noticed that foreign tax havens aren't so reliable, so we'll try some domestic tax havens for a change. We'll bite the bullet and probably have to pay twice the tax we had to pay in Ireland (which would probably be a whooping 0.01% instead of the 0.005% so far).

    --
    We used to have a Bill of Rights. Now, with the rights gone, all we have left is the bill.
  51. The people up top by Anonymous Coward · · Score: 0

    had a word with him, and the word was that you can't let the tax money fall in the hands of the EU, give them to your own country's government instead.

  52. Billions by bestweasel · · Score: 1

    "We paid $400m to Ireland, we paid $400 (million) to the US and we provisioned several billion dollars for the US for payment as soon as we repatriate it and right now I forecast that repatriation to occur next year," he said.

    To put this in perspective, Apple makes several billion dollars profit every month.

  53. Pay your tax and demand something for it by Anonymous Coward · · Score: 0

    If you think about it what has been happening here it is insane. Companies like Apple are getting into an effective tax range of 1-5% on their profit.
    The purpose of paying taxes is that you get a benefit out of it. I am happy to pay taxes as long as I then have very good roads, a good school system for my kids, decent healthcare, etc, etc.

    When you want to do business in a country and that country has a tax setup where companies also pay taxes in their profit, the pay it! It equalises the playing field for all and truly makes the competition fair. The better product, service, setup will win.

    In this case companies move money between countries by using the tax rules agains eachother. In the case of StarBucks the royalties on the brand and the profit on that are not taxable in Ireland. Profit in the UK on their actual operation are taxable in the UK. If I now increase my costbase by charging just enough royalties (the right to put starbucks on the window and use the brand) to make the profit close to zero......... we are all smart enough to do the math I presume.

    The rule should be that when you make profit in a country, you pay taxes in that country: Period! This way we all get an equal playingfield and companies actually start to contribute to the societies they are making a profit on. I am sure that with this system we will all benefit, including the companies themselves.

  54. Pay your tax and demand something for it. by sp4ni3l · · Score: 1

    If you think about it what has been happening here it is insane. Companies like Apple are getting into an effective tax range of 1-5% on their profit. The purpose of paying taxes is that you get a benefit out of it. I am happy to pay taxes as long as I then have very good roads, a good school system for my kids, decent healthcare, etc, etc. When you want to do business in a country and that country has a tax setup where companies also pay taxes in their profit, the pay it! It equalises the playing field for all and truly makes the competition fair. The better product, service, setup will win. In this case companies move money between countries by using the tax rules agains eachother. In the case of StarBucks the royalties on the brand and the profit on that are not taxable in Ireland. Profit in the UK on their actual operation are taxable in the UK. If I now increase my costbase by charging just enough royalties (the right to put starbucks on the window and use the brand) to make the profit close to zero......... we are all smart enough to do the math I presume. The rule should be that when you make profit in a country, you pay taxes in that country: Period! This way we all get an equal playingfield and companies actually start to contribute to the societies they are making a profit on. I am sure that with this system we will all benefit, including the companies themselves. Reply to This

  55. Only going to get worse by bigdavex · · Score: 1

    Creative accounting has made corporate taxes for international companies obsolete. Tax consumption, not production. Apple Execs buy pizza and mansions somewhere. Tax those things.

    --
    -Dave
    1. Re:Only going to get worse by Anonymous Coward · · Score: 0
      But taxing consumption places a much higher burden on those with the least money, as they have to consume more.

      The rich invest it instead, and with your system make even more free money that they don't really spend either.

    2. Re:Only going to get worse by bigdavex · · Score: 1

      But taxing consumption places a much higher burden on those with the least money, as they have to consume more.

      What? No they don't.

      The rich invest it instead, and with your system make even more free money that they don't really spend either.

      So the social injustice here is that the rich people don't have to work. True enough. The way we're doing it now, rich people don't work AND they consume much more than poor people.

      --
      -Dave
  56. Question by Anonymous Coward · · Score: 0

    Watching this show, I have a question about what options are available to Apple.

    By an amazing process, Apple actually does real, physical things which make neat products which real people buy and use.
    Lets call this process X. For argument, say it includes US designing things, China making things, and the EU buying things.

    By a more amazing process, Apple creates a less real process for tax purposes.
    Lets call this process Y. For argument Y includes Apple Caymen and Apple Ireland as physical bystanders, but financial principals.

    I'm ok with the rule that says that an entity can and should arrange their affairs to minimize their tax obligation.
    Arranging affairs should certainly include choosing what real, physical acts between willing, independent buyers and sellers. (like X)
    It's less clear to me that arranging should include choosing how to describe your operations for tax purposes. (like Y)
    But it looks like the Y stuff is a real part of the game.

    So if the EU is changing the effective rules in mid game, and Y is simply a fiction for taxes, does Apple get to change Y in mid game.
    That is, do the get to refile their taxes and say that now instead of Y, they would like to use a new description Z instead?

    Surely they have plenty of random corporate entities lying around and they could 'discover' a different one of these actually 'made' the money.

    This is tax stuff is a confusing game. I'm having a hard time seeing the rules. (If there are any.)

  57. I got news for ya! by ArchieBunker · · Score: 1

    Do you think corporations will absorb these extra taxes and take less income, or pass the increases along to the customers?

    --
    Only the State obtains its revenue by coercion. - Murray Rothbard
  58. This may well be related to the tax bill in irelan by petermgreen · · Score: 1

    AIUI the USA charges corporations on their global profits but

    1. It gives them credits for foreign tax paid on foreign profit.
    2. Profits made by foreign subsidaries are only taxed when they are "realised" by the parent company.

    Apple has been avoiding taxes in Europe. This has left them with a lot of profits in their European subsidaries which they can't bring back to the US without a large tax bill. If they end up having to pay taxes in Europe, they would be able to claim credit for those taxes when bringing the money home.

    --
    note: i'm known as plugwash most places but i screwd up registering that here somehow in the past and now can't register
  59. Re:meh by NotAPK · · Score: 1

    "He likes to show but just want to go out in the rain, when there are less people on the street. (Or just want to make fun, which is the standard response to any attitude of who does bitching here)"

    Source: Google Translate.

  60. Re: rats fleeing the sinking ship by cunina · · Score: 1

    Right on, brother! In the same vein, I hereby declare piracy to be theft, because that's illegal too!

  61. Oh what tangled webs we weave by Anonymous Coward · · Score: 0

    One would almost think this is an iTaxAvoidance

  62. Time to close the loopholes by Anonymous Coward · · Score: 0

    Its well past time to close the loopholes. 2017 should be the year that profits made in the past 20 years in the US must be paid in the US, and at current rates. Fines, interest, and interest on the fines for late payers are all applicable. "We don't care what Ireland does, or the EU or the Grand Cayman Islands, if you made the profits here, you pay the taxes here!" Oh, and if you don't like US taxes, don't sell product there.

  63. They can try the scare as much as they want by aepervius · · Score: 1

    0.0005% tax threat loss is not worth being scared. Even ireland can eat that one.

    --
    C. Sagan : A demon haunted world:
    http://www.amazon.com/gp/product/0345409469/
    visit randi.org
  64. Not really by Anonymous Coward · · Score: 0

    "Basically the only country in the world that will keep fucking you over even after you try to leave it behind for ever. Glad I'm not a 'citizen'."

    As soon as you stop being an US citizen you stop paying that tax. So no not really forever.

  65. Mods by Anonymous Coward · · Score: 0

    Score high:
    "US, a country known to deny effective council, torture people and lock up people without trial"

    Mmm hm.

  66. CLINTON 2016 by Anonymous Coward · · Score: 0

    Clinton is a square shooter. Clinton 2016!