He didn't disclose his interest, and is suspected of funding the other objectors who've pushed this further beyond all reason.
The reason for the challenges is that permission was granted for one datacenter, but Apple had said that they planned on later asking for permission for up to 7 more. All the objections were based on the full "Masterplan" of 8 halls, but the permission was only given for one. So the Environmental Impact Assessment, power requirements, hydrological assessment, and all the other paperwork was for the one hall. The objections claimed it should have been for all 8. Load of nonsense if you ask me, and the courts all the way to the high court agreed, but the objectors then got leave to appeal to the Supreme Court on some point of law (which must be pretty obscure because no-one has explained it), and the Supreme Court said that this would probably have to be referred to the European Court of Justice as whatever the point is must be based on EU law.
Nothing would ever get done if this was the way things were approached. It was "1 data center and up to 7 others depending on planning approval", not "8 data centers".
why are people so damn determined that "Obama did the same"
Obama had a facebook app that you had to install, that told you what it was doing and that you agreed to what it was doing. It did not suck in all your connections data against the TOS and your own preferences. It did not "scrape". There has never been any hint of it, and you can be sure there _would_ be if it had happened because these are the times we live in.
What Cambridge Analytica did was against the platform TOS, probably illegal, and they are being hauled over the coals for it. Rightly so, no matter who it was for.
One of the really interesting theories there was that it was forest bounceback after the massive die-off. The forests expanded rapidly for a century. One of the planks (sorry, couldn't resist) of any realistic decarbonization strategy should include massive tree planting and forest expansion. That is something that can be started now - there is a lot of marginal farmland that could be used for this all over the world. Stopping the deforestation of the Amazon basin is also critical.
The entire point of the liability shift was to try and reduce the card present fraud in the system. The level of skimming and cloning in the US is outrageous when fixes for the very issue were in use worldwide for decades. Even chip and signature puts a dent in it because the chip effectively cannot be cloned. The acquiring banks that lease the equipment to the merchants and process their transactions had - literally - no incentive to update. They were rolling out updated equipment that still did not support chip until a couple of years ago, which was criminal. Now the merchants are getting a taste of how widespread the problem is, they are pressuring the acquirers into upgrading. The really big merchants have already converted but they manage their own systems in house (like Walmart) so now the mid-level retailers are starting to push. It'll get there. In much of Europe magstripe fallback is not allowed if your card is chip enabled and we manage, but it took time and it will probably be a decade or so before magstripe is phased out.
The reason for poor uptake is an argument between the merchants, acquiring banks, CC networks, and issuers. Basically, most of the merchants lease the equipment from the acquirers, and the the acquirers are the only ones who didn't actually suffer from fraud because the liability largely fell on the Network or Issuer. However, the Acquirers own all the equipment and don't want to pay for an update. There is a double cost for them there as they both have to update hardware (the terminals themselves) and the software (as their systems must be EMV enabled). The Merchants were not being impacted at the same levels as the network or issuers so there was no pressure on the acquirers to change.
The liability shift that occurred last year basically put the loss on the merchant if they don't support Chip, in the hopes that they would pressure the acquirers. It's happening, but slowly. Large organizations that own their own POS stuff have mostly switched over to chip and signature. This has largely cut out Card Present fraud where it's used because it is basically impossible to clone a chip card. Stolen cards can still be used however, until they're cancelled. PIN would largely eliminate this also.
EMV doesn't really address Card Not Present (such as internet) fraud and won't until everyone has a chip reader attached to their computer.
You clearly didn't read the book, then. There was a place for everyone, although people were explicitly discouraged from doing it.
"But if you want to serve and I can't talk you out of it, then we have to take you, because that's your constitutional right. It says that everybody, male or female, should have his born right to pay his service and assume full citizenship— but the facts are that we are getting hard pushed to find things for all the volunteers to do that aren't just glorified KP. You can't all be real military men; we don't need that many and most of the volunteers aren't number-one soldier material anyhow...[W]e've had to think up a whole list of dirty, nasty, dangerous jobs that will...at the very least make them remember for the rest of their lives that their citizenship is valuable to them because they've paid a high price for it...A term of service is...either real military service, rough and dangerous even in peacetime...or a most unreasonable facsimile thereof."
If you had no arms and no legs you'd be put to testing new design of survival suits on Titan or something else hazardous.
The primary reason for the move is that mag-stripe skimming and cloning is so simple that it's costing the merchants and the card networks billions. The only people who don't care are the customers (because it doesn't affect them) and the acquiring banks (because they don't eat the charges). The delays in adopting are all about cost. The US was the first place to go with card payments, so you guys have the oldest infrastructure, and unlike most of Europe where the issuing banks also acquire and so can direct the market more, most acquiring banks in the US are specialists and don't necessarily issue.
This lead to a situation where the owner of the hardware has no incentive to upgrade to EMV, and it doesn't cost them anything. The Merchants, Card Networks, and Issuers are all affected but the the customers aren't. So the Acquiring banks want someone else to pay for the update, the Merchants don't want to pay extra, the Issuers and Card Networks won't pay because it's not their hardware and the customers don't like change anyway so there's no pressure from that direction. The EMV adoption forum spent years pissing and moaning about the cost, until the networks (primarily Mastercard and Visa) just said "on and from this date we are no longer accepting any liability for non EMV card-present fraud" and then spent the bulk of the rest of the time complaining that they didn't have enough time to implement Chip and PIN, so we ended up with Chip and Signature which was surprisingly effective - it basically negates card cloning fraud (except for some sophisticated, expensive and difficult to scale methods) - but does not prevent stolen-card fraud.
European banks hate their customers using cards in the US, because they are so frequently cloned and scammed. Going to the US you need two cards and cash - one backup card for when the first is cloned and has to be cancelled, and cash in case you're unlucky enough to have it happen twice.
For the 7 - 10 upgrade, it actively uninstalls programs if it's unsure about compatibility. In my case it was quite a long list including games, text editors, and other software.
It does give you a list of them afterwards though, so I guess that's nice.
Pyonyang has been financing itself for years by cyber attacks on large banks - they have quite sophisticated hacking abilities. They've also been under sustained cyber attack themselves (if a NK missile goes walkabout on test firing there's a fair chance it was compromised although it's not definite because they do have other quality issues) so I assume that they are reasonably sophisticated in cyber defense.
I seem to be missing your point, I think. For this case it's irrelevant how "important" Ireland is to Apple (a distinction I'm not sure I understand what you mean by) - what matters is whether the tax regime used by Apple (strictly speaking, the corporate structure that Apple used to move money about) was available to everyone or not. Ireland say it was, the EU say nu-uh.
The EU countries are allowed to compete on tax, and indeed Luxembourg is well known for this. All countries incentivize particular industries in various ways which incentivizes behaviour. Holland levies particularly low taxes on transfers to outside the EU, which Ireland doesn't. Ireland only taxes corporate profits earned inside Ireland, whereas France and Germany only tax corporate profits booked inside their borders. France has a corporation tax rate of 35% that no one actually pays - the rate that was until recently advertised on their industrial development agency's website was somewhere around 6% due to various incentives. The UK is generous around bonuses, whereas all income in Ireland is taxable (if you get a company car, you pay income tax on the value of it - we don't get company cars here).
The thing is that morally, sure, the structure stinks. But legally the EU's case is very, very shaky. For one thing, the.0002 tax rate assumes all global income would be taxed, which is just not true under Irish tax law. For another, Apple requested advice and received clearance from the Irish Revenue Commissioners about this. So it will go to court, and no-one except the lawyers will win, as always.
That said, forget about the common corporate tax base (which is what this appears to be about behind the scenes) but the EU countries should agree a common approach to assess what income is taxable. This would close most of the loopholes that the money is pouring through at the moment, and would appear to be easier to agree on than, say, an EU-wide minimum corporate tax.
At the time, there were no other companies. This goes all the way back to 1976 when Ireland had bugger all industry of any kind. To attract investment Ireland offered generous tax levels, generous tax rebates and write-offs, particularly in the area of R&D. Other companies use and have used similar programmes of course (Dell, for instance, took 10 years of generous tax rates and when the deal expired promptly moved all the manufacturing off to Poland or Hungary). It's just that Apple having been here longer, got a larger benefit.
This continues until today, and indeed is used by all countries (we currently incentivize R&D work at >100% tax write off so the more research you do here, the less tax you have to pay).
How is this relevant to either the great-grandparent post (claiming that Apple Ireland was barely a fig leaf because there were so few workers) and my original post (which pointed out that 4,000 people isn't a brass-plate operation)?
Ireland, as it turns out, is important to Apple or they wouldn't base so many people there for so long. Similarly, Google, IBM, Facebook, Intel, Cisco, HP, Eriksson, Analog, Dell/EMV, Microsoft - all the biggest European and American technology firms have substantial operations in Ireland in Dublin, Cork, Limerick, Galway, Leixlip and Athlone. Up until a few years ago they absolutely could have been two guys and a dog, and it wasn't on anyone's hitlist. But all of them employ thousands of people in development, manufacturing, sales, customer support and finance. Hell, Dell moved it's entire 5,000 person EU manufacturing hub out of Ireland and still employs over a thousand people before they bought EMC (which added thousands more).
So it's more than taxes, although that's part of an overall attractive package that includes close cultural ties with America, native English speaking with strong second language skills, and good education.
Doesn't this just end up boiling down to higher effective taxes?
For companies the size and structure of Apple, yes it does, although then they'd move on to more aggressive transfer pricing or something else.
My general sense is that the larger problem isn't paying or not paying taxes, its the cash hoarding these semi-monopoly companies do. A lot of the money just ends up in short-term treasuries or other semi-liquid investment vehicles and doesn't circulate in the economy. In some ways, taxes can be seen as the economic investment of last resort -- a way to bring hoarded capital into the market.
Yes, I tend to agree with this, although the not-paying of taxes is a contributory factor in the cash hoarding.The cash hoards get so large in part because of the tax avoidance. A further factor is the US corporation tax rules, and rates, which are very high.
A better policy would seem to be incentives to spend and not hoard capital so it gets put into motion in the economy.
Easier said than done! Although companies have figured out some ways around this, Apple again being one of the innovators. If they need liquidity in the States that they don't have (because their dragon's hoard is in Barbados) they simply borrow. The cash hoard is collateral, and the interest rates are very, very low because Apple are not a default risk with 200 billion dollars lying about behind the couch. So they have liquidity where they need it without giving up 35% of their money. Apple don't care about their 200 billion being offshore and (technically) inaccessible because there is nothing they want or need to do with it that they can't do out of normal revenue (which they'll probably get a tax break for) or cheap loans.
On a more general point, a further problem is that at the moment, business capital is not in short supply due to the very low interest rates so there's capital looking for opportunities. Historically we can say this is a dangerous situation as this situation can lead to a tendency to inflate stocks which can lead to a bubble/burst situation. Taxes could soak up some of this excess capital and allow it to be spent on the collective in the form of public infrastructure but at the moment it is difficult to tax and business largely have no reason to invest in public infrastructure. So the money is static (as in it is not circulating) and at a time when the US is richer than at any time in its history it has infrastructure problems and those who could be employed in fixing it are idle.
Actually, that's not correct. They're enforcing an agreement that all companies inside a jurisdiction have to be treated the same. If Ireland wanted 0% corporate tax, and applied that to everyone that would be inside the rules. What the Commission decided is that the deal Apple got was an unfair subsidy because no-one else used it. Ireland and Apple say that it was available to everyone, so it wasn't a subsidy and it wasn't unfair.
The double Irish tax maneuver is worthless on its own without the Dutch sandwich.
The double Irish involves having an Irish registered company legally headquartered elsewhere than the EU (like the Caymans) as well as an Irish registered company headquartered in the EU. This used to be allowed, but it is not allowed any more (and existing structures of this sort have to wind down over the next few years).
There are two components to this. First, the Irish tax is based on where the income is made and only tax Irish income, so do not tax based on income from sales outside the country. This seems reasonable on it's own, but it interacts with other countries tax rules which tax based on where the income is booked. As a result, a company can book profits in Ireland, and fall into the gap between these positions.
The second component is profit moving - the resultant profits can be moved between the resident company and the non-resident company at no (or extremely low) taxes, but moving the money out of the EU to the external HQ would be taxed heavily from Ireland. However, this is not taxed heavily in Holland (due to historical attachments to the Dutch Antilles). So the organization move the money to Holland (inter-EU transfer, low tax), and from that subsidiary to the tax haven (Dutch law, low tax) and then have it in a tax haven for a very low cost. Where they sit on it because the US tax is punishing.
The solution is not higher taxes, it's closing these gaps that companies exploit.
The fact that the Irish branch barely employs any people and is largely just a convenient IP holder makes this even more blatant.
Apple Ireland employs around 4,000 people in Cork, in areas from sales to finance to customer support. It's a major employer in the city and has been for over 30 years, where it used to provide a lot of manufacturing jobs (few of these are left now). The only country in the EU with more Apple employees is the UK, where the number of Apple retail stores (37) explains the difference.
You explicitly penned away the right to do what you're doing here.
The EU maintains that Ireland gave Apple preferential tax treatment that was not available to others and thus amounts to a subsidy which Apple must now repay. We agreed not to give subsidies under EU treaty.
Ireland maintains that we put in place an attractive tax regime available to all to encourage FDI. This is allowed under EU treaty and law, and in fact is used by all EU nations.
So if the EU are right, we get roughly 13 billion in back taxes from Apple. If the EU are wrong (which I believe they are) then we don't. The reason that this is so heated is that it at the edges (Apple were the only company to take advantage of the rules at the start) and there is a worry that this is an overreach by the EU commission which affects the ability of the government to levy its own taxes, which the the countries making up the EU have agreed is up to the individual countries.
S7 has an SD card slot and a headphone jack. The battery is not removable but it is a good sized battery that lasts well. The phone is also waterproof and sturdy, feels solid (if a little slippy) and performs very well. Perhaps you were thinking of the S6 (which had a diabolical battery and no SD card slot)?
Basic misreading of the summary there, old chap (or chapette). The market for Global Positioning services is estimated to be worth 250 billion euro a year by 2020, but this is not the cost of Galileo.
It was budgeted at 3.4 billion euro which turned out to be, er, optimistic - it looks now like it will be somewhere between 5.5 and 7 billion euro (including the running costs for 20 years in that brings it up to ~20 billion). On the flip side, approximately 7% of EU GDP is dependent on satellite navigation worth a total of 800 billion.
Come on, you can't blame Hillary for Libya. That was clearly the UK and France, and the US got roped in based on the fact that their two biggest allies basically begged.
That you think that the System.gc() call invokes the garbage collector is the kind of thing I hate about the garbage collector. The System.gc() call does not call the garbage collector, it notifies the collector that there is garbage to be collected and the JVM still makes the scheduling decision. In practice it may lead to immediate garbage collection, but that is not necessarily the case.
Secondly, you CAN specify your own garbage collector or specify one-of-the-many that exist, but an explicit call to System.gc() usually forces the collector to check if all the objects still allocated are reachable so the process can be quite inefficient. If you're using Java, calls to System.gc() should be very rare.
Lastly (to clarify something i said above, and this is not the garbage collector's issue) the JVM heap size rises independently of the Java allocations so garbage collecting doesn't return heap to the system.
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He didn't disclose his interest, and is suspected of funding the other objectors who've pushed this further beyond all reason.
The reason for the challenges is that permission was granted for one datacenter, but Apple had said that they planned on later asking for permission for up to 7 more. All the objections were based on the full "Masterplan" of 8 halls, but the permission was only given for one. So the Environmental Impact Assessment, power requirements, hydrological assessment, and all the other paperwork was for the one hall. The objections claimed it should have been for all 8. Load of nonsense if you ask me, and the courts all the way to the high court agreed, but the objectors then got leave to appeal to the Supreme Court on some point of law (which must be pretty obscure because no-one has explained it), and the Supreme Court said that this would probably have to be referred to the European Court of Justice as whatever the point is must be based on EU law.
Nothing would ever get done if this was the way things were approached. It was "1 data center and up to 7 others depending on planning approval", not "8 data centers".
why are people so damn determined that "Obama did the same"
Obama had a facebook app that you had to install, that told you what it was doing and that you agreed to what it was doing. It did not suck in all your connections data against the TOS and your own preferences. It did not "scrape". There has never been any hint of it, and you can be sure there _would_ be if it had happened because these are the times we live in.
What Cambridge Analytica did was against the platform TOS, probably illegal, and they are being hauled over the coals for it. Rightly so, no matter who it was for.
One of the really interesting theories there was that it was forest bounceback after the massive die-off. The forests expanded rapidly for a century. One of the planks (sorry, couldn't resist) of any realistic decarbonization strategy should include massive tree planting and forest expansion. That is something that can be started now - there is a lot of marginal farmland that could be used for this all over the world. Stopping the deforestation of the Amazon basin is also critical.
The entire point of the liability shift was to try and reduce the card present fraud in the system. The level of skimming and cloning in the US is outrageous when fixes for the very issue were in use worldwide for decades. Even chip and signature puts a dent in it because the chip effectively cannot be cloned. The acquiring banks that lease the equipment to the merchants and process their transactions had - literally - no incentive to update. They were rolling out updated equipment that still did not support chip until a couple of years ago, which was criminal.
Now the merchants are getting a taste of how widespread the problem is, they are pressuring the acquirers into upgrading. The really big merchants have already converted but they manage their own systems in house (like Walmart) so now the mid-level retailers are starting to push. It'll get there. In much of Europe magstripe fallback is not allowed if your card is chip enabled and we manage, but it took time and it will probably be a decade or so before magstripe is phased out.
The reason for poor uptake is an argument between the merchants, acquiring banks, CC networks, and issuers. Basically, most of the merchants lease the equipment from the acquirers, and the the acquirers are the only ones who didn't actually suffer from fraud because the liability largely fell on the Network or Issuer. However, the Acquirers own all the equipment and don't want to pay for an update. There is a double cost for them there as they both have to update hardware (the terminals themselves) and the software (as their systems must be EMV enabled). The Merchants were not being impacted at the same levels as the network or issuers so there was no pressure on the acquirers to change.
The liability shift that occurred last year basically put the loss on the merchant if they don't support Chip, in the hopes that they would pressure the acquirers. It's happening, but slowly. Large organizations that own their own POS stuff have mostly switched over to chip and signature. This has largely cut out Card Present fraud where it's used because it is basically impossible to clone a chip card. Stolen cards can still be used however, until they're cancelled. PIN would largely eliminate this also.
EMV doesn't really address Card Not Present (such as internet) fraud and won't until everyone has a chip reader attached to their computer.
You clearly didn't read the book, then. There was a place for everyone, although people were explicitly discouraged from doing it.
"But if you want to serve and I can't talk you out of it, then we have to take you, because that's your constitutional right. It says that everybody, male or female, should have his born right to pay his service and assume full citizenship— but the facts are that we are getting hard pushed to find things for all the volunteers to do that aren't just glorified KP. You can't all be real military men; we don't need that many and most of the volunteers aren't number-one soldier material anyhow...[W]e've had to think up a whole list of dirty, nasty, dangerous jobs that will...at the very least make them remember for the rest of their lives that their citizenship is valuable to them because they've paid a high price for it...A term of service is...either real military service, rough and dangerous even in peacetime...or a most unreasonable facsimile thereof."
If you had no arms and no legs you'd be put to testing new design of survival suits on Titan or something else hazardous.
You must be joking!
The primary reason for the move is that mag-stripe skimming and cloning is so simple that it's costing the merchants and the card networks billions. The only people who don't care are the customers (because it doesn't affect them) and the acquiring banks (because they don't eat the charges). The delays in adopting are all about cost. The US was the first place to go with card payments, so you guys have the oldest infrastructure, and unlike most of Europe where the issuing banks also acquire and so can direct the market more, most acquiring banks in the US are specialists and don't necessarily issue.
This lead to a situation where the owner of the hardware has no incentive to upgrade to EMV, and it doesn't cost them anything. The Merchants, Card Networks, and Issuers are all affected but the the customers aren't. So the Acquiring banks want someone else to pay for the update, the Merchants don't want to pay extra, the Issuers and Card Networks won't pay because it's not their hardware and the customers don't like change anyway so there's no pressure from that direction. The EMV adoption forum spent years pissing and moaning about the cost, until the networks (primarily Mastercard and Visa) just said "on and from this date we are no longer accepting any liability for non EMV card-present fraud" and then spent the bulk of the rest of the time complaining that they didn't have enough time to implement Chip and PIN, so we ended up with Chip and Signature which was surprisingly effective - it basically negates card cloning fraud (except for some sophisticated, expensive and difficult to scale methods) - but does not prevent stolen-card fraud.
European banks hate their customers using cards in the US, because they are so frequently cloned and scammed. Going to the US you need two cards and cash - one backup card for when the first is cloned and has to be cancelled, and cash in case you're unlucky enough to have it happen twice.
For the 7 - 10 upgrade, it actively uninstalls programs if it's unsure about compatibility. In my case it was quite a long list including games, text editors, and other software.
It does give you a list of them afterwards though, so I guess that's nice.
Pyonyang has been financing itself for years by cyber attacks on large banks - they have quite sophisticated hacking abilities. They've also been under sustained cyber attack themselves (if a NK missile goes walkabout on test firing there's a fair chance it was compromised although it's not definite because they do have other quality issues) so I assume that they are reasonably sophisticated in cyber defense.
I was under the impression she hired an external law firm to determine which were which, and did not use her own people.
But this gets to the issue nicely - her private email server existed to bypass FOIA requests. Which was illegal. Period.
That's an assertion which is presuming knowledge of Hillary Clinton's intentions, so can't really be backed up.
What do you think "black holes" are?
I seem to be missing your point, I think. For this case it's irrelevant how "important" Ireland is to Apple (a distinction I'm not sure I understand what you mean by) - what matters is whether the tax regime used by Apple (strictly speaking, the corporate structure that Apple used to move money about) was available to everyone or not. Ireland say it was, the EU say nu-uh.
The EU countries are allowed to compete on tax, and indeed Luxembourg is well known for this. All countries incentivize particular industries in various ways which incentivizes behaviour. Holland levies particularly low taxes on transfers to outside the EU, which Ireland doesn't. Ireland only taxes corporate profits earned inside Ireland, whereas France and Germany only tax corporate profits booked inside their borders. France has a corporation tax rate of 35% that no one actually pays - the rate that was until recently advertised on their industrial development agency's website was somewhere around 6% due to various incentives. The UK is generous around bonuses, whereas all income in Ireland is taxable (if you get a company car, you pay income tax on the value of it - we don't get company cars here).
The thing is that morally, sure, the structure stinks. But legally the EU's case is very, very shaky. For one thing, the .0002 tax rate assumes all global income would be taxed, which is just not true under Irish tax law. For another, Apple requested advice and received clearance from the Irish Revenue Commissioners about this. So it will go to court, and no-one except the lawyers will win, as always.
That said, forget about the common corporate tax base (which is what this appears to be about behind the scenes) but the EU countries should agree a common approach to assess what income is taxable. This would close most of the loopholes that the money is pouring through at the moment, and would appear to be easier to agree on than, say, an EU-wide minimum corporate tax.
At the time, there were no other companies. This goes all the way back to 1976 when Ireland had bugger all industry of any kind. To attract investment Ireland offered generous tax levels, generous tax rebates and write-offs, particularly in the area of R&D. Other companies use and have used similar programmes of course (Dell, for instance, took 10 years of generous tax rates and when the deal expired promptly moved all the manufacturing off to Poland or Hungary). It's just that Apple having been here longer, got a larger benefit.
This continues until today, and indeed is used by all countries (we currently incentivize R&D work at >100% tax write off so the more research you do here, the less tax you have to pay).
How is this relevant to either the great-grandparent post (claiming that Apple Ireland was barely a fig leaf because there were so few workers) and my original post (which pointed out that 4,000 people isn't a brass-plate operation)?
Ireland, as it turns out, is important to Apple or they wouldn't base so many people there for so long. Similarly, Google, IBM, Facebook, Intel, Cisco, HP, Eriksson, Analog, Dell/EMV, Microsoft - all the biggest European and American technology firms have substantial operations in Ireland in Dublin, Cork, Limerick, Galway, Leixlip and Athlone. Up until a few years ago they absolutely could have been two guys and a dog, and it wasn't on anyone's hitlist. But all of them employ thousands of people in development, manufacturing, sales, customer support and finance. Hell, Dell moved it's entire 5,000 person EU manufacturing hub out of Ireland and still employs over a thousand people before they bought EMC (which added thousands more).
So it's more than taxes, although that's part of an overall attractive package that includes close cultural ties with America, native English speaking with strong second language skills, and good education.
Doesn't this just end up boiling down to higher effective taxes?
For companies the size and structure of Apple, yes it does, although then they'd move on to more aggressive transfer pricing or something else.
My general sense is that the larger problem isn't paying or not paying taxes, its the cash hoarding these semi-monopoly companies do. A lot of the money just ends up in short-term treasuries or other semi-liquid investment vehicles and doesn't circulate in the economy. In some ways, taxes can be seen as the economic investment of last resort -- a way to bring hoarded capital into the market.
Yes, I tend to agree with this, although the not-paying of taxes is a contributory factor in the cash hoarding .The cash hoards get so large in part because of the tax avoidance. A further factor is the US corporation tax rules, and rates, which are very high.
A better policy would seem to be incentives to spend and not hoard capital so it gets put into motion in the economy.
Easier said than done! Although companies have figured out some ways around this, Apple again being one of the innovators. If they need liquidity in the States that they don't have (because their dragon's hoard is in Barbados) they simply borrow. The cash hoard is collateral, and the interest rates are very, very low because Apple are not a default risk with 200 billion dollars lying about behind the couch. So they have liquidity where they need it without giving up 35% of their money. Apple don't care about their 200 billion being offshore and (technically) inaccessible because there is nothing they want or need to do with it that they can't do out of normal revenue (which they'll probably get a tax break for) or cheap loans.
On a more general point, a further problem is that at the moment, business capital is not in short supply due to the very low interest rates so there's capital looking for opportunities. Historically we can say this is a dangerous situation as this situation can lead to a tendency to inflate stocks which can lead to a bubble/burst situation. Taxes could soak up some of this excess capital and allow it to be spent on the collective in the form of public infrastructure but at the moment it is difficult to tax and business largely have no reason to invest in public infrastructure. So the money is static (as in it is not circulating) and at a time when the US is richer than at any time in its history it has infrastructure problems and those who could be employed in fixing it are idle.
Actually, that's not correct. They're enforcing an agreement that all companies inside a jurisdiction have to be treated the same. If Ireland wanted 0% corporate tax, and applied that to everyone that would be inside the rules. What the Commission decided is that the deal Apple got was an unfair subsidy because no-one else used it. Ireland and Apple say that it was available to everyone, so it wasn't a subsidy and it wasn't unfair.
The double Irish tax maneuver is worthless on its own without the Dutch sandwich.
The double Irish involves having an Irish registered company legally headquartered elsewhere than the EU (like the Caymans) as well as an Irish registered company headquartered in the EU. This used to be allowed, but it is not allowed any more (and existing structures of this sort have to wind down over the next few years).
There are two components to this. First, the Irish tax is based on where the income is made and only tax Irish income, so do not tax based on income from sales outside the country. This seems reasonable on it's own, but it interacts with other countries tax rules which tax based on where the income is booked. As a result, a company can book profits in Ireland, and fall into the gap between these positions.
The second component is profit moving - the resultant profits can be moved between the resident company and the non-resident company at no (or extremely low) taxes, but moving the money out of the EU to the external HQ would be taxed heavily from Ireland. However, this is not taxed heavily in Holland (due to historical attachments to the Dutch Antilles). So the organization move the money to Holland (inter-EU transfer, low tax), and from that subsidiary to the tax haven (Dutch law, low tax) and then have it in a tax haven for a very low cost. Where they sit on it because the US tax is punishing.
The solution is not higher taxes, it's closing these gaps that companies exploit.
The fact that the Irish branch barely employs any people and is largely just a convenient IP holder makes this even more blatant.
Apple Ireland employs around 4,000 people in Cork, in areas from sales to finance to customer support. It's a major employer in the city and has been for over 30 years, where it used to provide a lot of manufacturing jobs (few of these are left now). The only country in the EU with more Apple employees is the UK, where the number of Apple retail stores (37) explains the difference.
So it's hardly a brass-plate operation.
You explicitly penned away the right to do what you're doing here.
The EU maintains that Ireland gave Apple preferential tax treatment that was not available to others and thus amounts to a subsidy which Apple must now repay. We agreed not to give subsidies under EU treaty.
Ireland maintains that we put in place an attractive tax regime available to all to encourage FDI. This is allowed under EU treaty and law, and in fact is used by all EU nations.
So if the EU are right, we get roughly 13 billion in back taxes from Apple. If the EU are wrong (which I believe they are) then we don't. The reason that this is so heated is that it at the edges (Apple were the only company to take advantage of the rules at the start) and there is a worry that this is an overreach by the EU commission which affects the ability of the government to levy its own taxes, which the the countries making up the EU have agreed is up to the individual countries.
Er, what?
S7 has an SD card slot and a headphone jack. The battery is not removable but it is a good sized battery that lasts well. The phone is also waterproof and sturdy, feels solid (if a little slippy) and performs very well. Perhaps you were thinking of the S6 (which had a diabolical battery and no SD card slot)?
The program is managed by the ESA.
Basic misreading of the summary there, old chap (or chapette). The market for Global Positioning services is estimated to be worth 250 billion euro a year by 2020, but this is not the cost of Galileo.
It was budgeted at 3.4 billion euro which turned out to be, er, optimistic - it looks now like it will be somewhere between 5.5 and 7 billion euro (including the running costs for 20 years in that brings it up to ~20 billion). On the flip side, approximately 7% of EU GDP is dependent on satellite navigation worth a total of 800 billion.
Come on, you can't blame Hillary for Libya. That was clearly the UK and France, and the US got roped in based on the fact that their two biggest allies basically begged.
That you think that the System.gc() call invokes the garbage collector is the kind of thing I hate about the garbage collector.
The System.gc() call does not call the garbage collector, it notifies the collector that there is garbage to be collected and the JVM still makes the scheduling decision. In practice it may lead to immediate garbage collection, but that is not necessarily the case.
Secondly, you CAN specify your own garbage collector or specify one-of-the-many that exist, but an explicit call to System.gc() usually forces the collector to check if all the objects still allocated are reachable so the process can be quite inefficient. If you're using Java, calls to System.gc() should be very rare.
Lastly (to clarify something i said above, and this is not the garbage collector's issue) the JVM heap size rises independently of the Java allocations so garbage collecting doesn't return heap to the system.