10 ms·

I can't argue with their rationale or yours, but would be totally comfortable with Pfizer being barred from lobbying now, as a foreign corporation, plus being h

by pnut 11y ago

I can't argue with their rationale or yours, but would be totally comfortable with Pfizer being barred from lobbying now, as a foreign corporation, plus being hit with import tariffs. No reason US law has to open taxpayers to blatant exploitation by multinational corporations, who probably benefit more than anyone, from the US' unique combination of highly educated workforce, stable and for-sale political system, protective military, and millions upon millions of the most prolific, indiscriminate consumers in the world.

tajen 11y ago
No reason the TPP has to open our taxpayers to blatant exploitation by US corporations who profit from US's protective military. - The rest of the world.
charlesdm 11y ago
Taxpayers aren't being exploited. The US just has a ridiculous tax policy, as the only western country in the world. How does it make sense to want to tax every single dollar, regardless of where it was earned? It makes total sense to do an inversion if you want to build a global company. Stopping (or at least reducing the amount of) inversions is easy. Just lower the corporate tax rate to an acceptable level. Large companies who are not doing inversion deals are often leaving billions on the table.
- toomuchtodo 11y ago
  > Stopping (or at least reducing the amount of) inversions is easy. Just lower the corporate tax rate to an acceptable level. So give in to terrorist demands? No. We institute duty on your products or services, we nullify your patents, we prohibit you access to the market. GTFO. What's that? You don't like that? Buck up princess, government exists to protect its citizens, not your corporate profits.
  - charlesdm 11y ago
    The problem lies in the fact that the US is all about free trade. They don't want to do that. You can't have it both ways. Situation one: I'm a US company, expanding abroad. I acquire foreign competitors, and build a global company. I'm taxed on every dollar (profit), since I'm a US (holding) company. Situation two: I'm a European company, expanding abroad. I acquire a US competitor, and build a global company. Since I'm a foreign company with foreign shareholders, the US can't tax my global income (obviously) This means a US company will be at a significant disadvantage to a UK/Swedish/Belgian company competing in the same market, because, even if their results are exactly the same, their after tax income will be significantly less. This also means that a US company bidding for a US competitor will be able to pay less than a foreign company buying up US companies, because they can achieve less/lower (tax) synergies.
  - arca_vorago 11y ago
    If only the people in positions of power took this stance, we would be in a much better place today. What bothers me is that the merger between corporations and state through k-street and the revolving door/regulatory capture has become exceedingly rampant.
  - Maarten88 11y ago
    > government exists to protect its citizens, not your corporate profits. That's how it should be. But from observation this seems not to be happening, at all. I wonder if someone could mention any example from the last years where the US government has clearly chosen against corporate interests, and for protecting its citizens.
    - Frondo 11y ago
      You want the consumer financial protection bureau: http://www.consumerfinance.gov/ http://www.consumerfinance.gov/ This is the thing Elizabeth Warren spearheaded, and the Republicans have fought tooth-and-nail since before it existed.
  - vezzy-fnord 11y ago
    Of course, the cost of duty is ultimately offloaded to the same citizens you're supposed to be protecting. Not to mention, the elephant in the room here is that no evasion is being performed, but avoidance. To equivocate the two would create a moral hazard that would also affect the same citizens you're supposed to be protecting.
    - toomuchtodo 11y ago
      Funny enough, a stroke of the legislative pen changes these activities from avoidance to evasion, no moral hazard required.
      - vezzy-fnord 11y ago
        How? Corporate mergers appear to be an intrinsically available strategy for avoiding an extraterritorial corporate tax system. What intervention will your legislative pen impose?
        toomuchtodo 11y ago
        > Corporate mergers appear to be an intrinsically available strategy for avoiding an extraterritorial corporate tax system. ...because of legislation and existing tax code allowing it. > What intervention will your legislative pen impose? I would have to speak with a legal associate with experience drafting legislation for specific language. The purposes would be to ensure any tax intended to specifically be avoided by a merger would be re-captured (this isn't out of the ordinary; the AMT in the US is specifically designed to disallow certain income tax deductions when a taxpayers income reaches a certain level, to prevent tax avoidance). My understanding is that the Double Irish Arrangement "loophole" has been closed, but further work needs to be done.
        vezzy-fnord 11y ago
        So, the business purpose and economic substance doctrines. Again, flimsy normative statements. A legislative pen obsessed with maximizing such a function will eventually write things unsavory to civil liberties, as well.
  - derriz 11y ago
    That's how business is done in places like Russia and China and in many very poor countries. Displease the government and face the full force of state power regardless of actual laws. I prefer being subject to laws and having recourse to a legal system where i am allowed to challenge even the behavior of the government. Subjecting corporations to capricious bullying when they do something unpopular is not "protecting citizens" - governments that act like that invariably also abuse individuals the same way.
    - toomuchtodo 11y ago
      > That's how business is done in places like Russia and China and in many very poor countries. Displease the government and face the full force of state power regardless of actual laws. Not at all. I'm suggesting the legislative process be used. You're inferring that trade protectionism is totalitarian rule. Seriously? Citizens and their quality of life is more important than you business and its profits. Full stop. > I prefer being subject to laws and having recourse to a legal system where i am allowed to challenge even the behavior of the government. But you are. If you operate in a country, you're subject to its laws. You have recourse under the legal system, and recourse for its legislation if you are a citizen and have a vote. > Subjecting corporations to capricious bullying when they do something unpopular is not "protecting citizens" - governments that act like that invariably also abuse individuals the same way. Today I learned that forcing companies to follow the spirit rather than the letter of the law is "bullying". Makes me found of how China and Russia do business sometimes.
      - vezzy-fnord 11y ago
        Citizens and their quality of life is more important than you business and its profits What do you think the mechanism for improving quality of life is? Trade.
        toomuchtodo 11y ago
        Not all trade improves quality of life, as I'm sure you're aware.
- rodgerd 11y ago
  > Just lower the corporate tax rate to an acceptable level. Since the acceptable level is 0, this is a stupid suggestion.
  - brandonmenc 11y ago
    The acceptable rate is that at which the accounting and legal cost of shuffling the company around for a tax break doesn't make sense. That may be closer to zero than you'd like, but it's certainly more than zero.
    - charlesdm 11y ago
      Exactly this. If the US would have a similar tax rate and policy to Ireland, this merger might not have happened. Many of these transactions are happening because they deliver quick, untapped gains. You just need to unlock them by doing an inversion deal. Or in other words, even an overpriced deal pays for itself.
      - Fuzzwah 11y ago
        But that can only happen if the US has a defense forces[1] spending similar to Ireland. [1] This is just the obvious example, include here any where that the US gov out spends the Irish.
- ericd 11y ago
  I'm certainly not 100% onboard with current tax policy, but it makes some sense when much of the value of the product being sold worldwide is created by US-based designers. Apple, for example - a huge portion of their value is created by their design teams in CA, but they make a huge fraction of their profits from those products by selling overseas.
  - Retric 11y ago
    You can't identify with any accuracy where profit showed up. R&D in country X, Y production in Y, Z sales in X, Y, Z, and A. Now, which country added profits. Except instead of X, Y, Z, it's ~150+ countries.
    - ericd 11y ago
      Yep, which is why we have simplified assumptions like "we tax everything at x rate", where x rate is likely lower lower than if they were successful at separating out what profit was made where.
  - ploxiln 11y ago
    Presumably Apple's design teams are well paid to keep producing all that value they produce, and the income taxes are captured in the US.
    - ericd 11y ago
      True. I don't subscribe to the idea that salaries are proportional to the value they create, though. Anyway, there are arguments to be made on both sides, and it's clearly not working very well.

by pnut 11y ago

tajen 11y ago

No reason the TPP has to open our taxpayers to blatant exploitation by US corporations who profit from US's protective military. - The rest of the world.

charlesdm 11y ago

Taxpayers aren't being exploited. The US just has a ridiculous tax policy, as the only western country in the world. How does it make sense to want to tax every single dollar, regardless of where it was earned? It makes total sense to do an inversion if you want to build a global company. Stopping (or at least reducing the amount of) inversions is easy. Just lower the corporate tax rate to an acceptable level. Large companies who are not doing inversion deals are often leaving billions on the table.

toomuchtodo 11y ago
> Stopping (or at least reducing the amount of) inversions is easy. Just lower the corporate tax rate to an acceptable level. So give in to terrorist demands? No. We institute duty on your products or services, we nullify your patents, we prohibit you access to the market. GTFO. What's that? You don't like that? Buck up princess, government exists to protect its citizens, not your corporate profits.
- charlesdm 11y ago
  The problem lies in the fact that the US is all about free trade. They don't want to do that. You can't have it both ways. Situation one: I'm a US company, expanding abroad. I acquire foreign competitors, and build a global company. I'm taxed on every dollar (profit), since I'm a US (holding) company. Situation two: I'm a European company, expanding abroad. I acquire a US competitor, and build a global company. Since I'm a foreign company with foreign shareholders, the US can't tax my global income (obviously) This means a US company will be at a significant disadvantage to a UK/Swedish/Belgian company competing in the same market, because, even if their results are exactly the same, their after tax income will be significantly less. This also means that a US company bidding for a US competitor will be able to pay less than a foreign company buying up US companies, because they can achieve less/lower (tax) synergies.
- arca_vorago 11y ago
  If only the people in positions of power took this stance, we would be in a much better place today. What bothers me is that the merger between corporations and state through k-street and the revolving door/regulatory capture has become exceedingly rampant.
- Maarten88 11y ago
  > government exists to protect its citizens, not your corporate profits. That's how it should be. But from observation this seems not to be happening, at all. I wonder if someone could mention any example from the last years where the US government has clearly chosen against corporate interests, and for protecting its citizens.
  - Frondo 11y ago
    You want the consumer financial protection bureau: http://www.consumerfinance.gov/ http://www.consumerfinance.gov/ This is the thing Elizabeth Warren spearheaded, and the Republicans have fought tooth-and-nail since before it existed.
- vezzy-fnord 11y ago
  Of course, the cost of duty is ultimately offloaded to the same citizens you're supposed to be protecting. Not to mention, the elephant in the room here is that no evasion is being performed, but avoidance. To equivocate the two would create a moral hazard that would also affect the same citizens you're supposed to be protecting.
  - toomuchtodo 11y ago
    Funny enough, a stroke of the legislative pen changes these activities from avoidance to evasion, no moral hazard required.
    - vezzy-fnord 11y ago
      How? Corporate mergers appear to be an intrinsically available strategy for avoiding an extraterritorial corporate tax system. What intervention will your legislative pen impose?
      - toomuchtodo 11y ago
        > Corporate mergers appear to be an intrinsically available strategy for avoiding an extraterritorial corporate tax system. ...because of legislation and existing tax code allowing it. > What intervention will your legislative pen impose? I would have to speak with a legal associate with experience drafting legislation for specific language. The purposes would be to ensure any tax intended to specifically be avoided by a merger would be re-captured (this isn't out of the ordinary; the AMT in the US is specifically designed to disallow certain income tax deductions when a taxpayers income reaches a certain level, to prevent tax avoidance). My understanding is that the Double Irish Arrangement "loophole" has been closed, but further work needs to be done.
        vezzy-fnord 11y ago
        So, the business purpose and economic substance doctrines. Again, flimsy normative statements. A legislative pen obsessed with maximizing such a function will eventually write things unsavory to civil liberties, as well.
- derriz 11y ago
  That's how business is done in places like Russia and China and in many very poor countries. Displease the government and face the full force of state power regardless of actual laws. I prefer being subject to laws and having recourse to a legal system where i am allowed to challenge even the behavior of the government. Subjecting corporations to capricious bullying when they do something unpopular is not "protecting citizens" - governments that act like that invariably also abuse individuals the same way.
  - toomuchtodo 11y ago
    > That's how business is done in places like Russia and China and in many very poor countries. Displease the government and face the full force of state power regardless of actual laws. Not at all. I'm suggesting the legislative process be used. You're inferring that trade protectionism is totalitarian rule. Seriously? Citizens and their quality of life is more important than you business and its profits. Full stop. > I prefer being subject to laws and having recourse to a legal system where i am allowed to challenge even the behavior of the government. But you are. If you operate in a country, you're subject to its laws. You have recourse under the legal system, and recourse for its legislation if you are a citizen and have a vote. > Subjecting corporations to capricious bullying when they do something unpopular is not "protecting citizens" - governments that act like that invariably also abuse individuals the same way. Today I learned that forcing companies to follow the spirit rather than the letter of the law is "bullying". Makes me found of how China and Russia do business sometimes.
    - vezzy-fnord 11y ago
      Citizens and their quality of life is more important than you business and its profits What do you think the mechanism for improving quality of life is? Trade.
      - toomuchtodo 11y ago
        Not all trade improves quality of life, as I'm sure you're aware.
rodgerd 11y ago
> Just lower the corporate tax rate to an acceptable level. Since the acceptable level is 0, this is a stupid suggestion.
- brandonmenc 11y ago
  The acceptable rate is that at which the accounting and legal cost of shuffling the company around for a tax break doesn't make sense. That may be closer to zero than you'd like, but it's certainly more than zero.
  - charlesdm 11y ago
    Exactly this. If the US would have a similar tax rate and policy to Ireland, this merger might not have happened. Many of these transactions are happening because they deliver quick, untapped gains. You just need to unlock them by doing an inversion deal. Or in other words, even an overpriced deal pays for itself.
    - Fuzzwah 11y ago
      But that can only happen if the US has a defense forces[1] spending similar to Ireland. [1] This is just the obvious example, include here any where that the US gov out spends the Irish.
ericd 11y ago
I'm certainly not 100% onboard with current tax policy, but it makes some sense when much of the value of the product being sold worldwide is created by US-based designers. Apple, for example - a huge portion of their value is created by their design teams in CA, but they make a huge fraction of their profits from those products by selling overseas.
- Retric 11y ago
  You can't identify with any accuracy where profit showed up. R&D in country X, Y production in Y, Z sales in X, Y, Z, and A. Now, which country added profits. Except instead of X, Y, Z, it's ~150+ countries.
  - ericd 11y ago
    Yep, which is why we have simplified assumptions like "we tax everything at x rate", where x rate is likely lower lower than if they were successful at separating out what profit was made where.
- ploxiln 11y ago
  Presumably Apple's design teams are well paid to keep producing all that value they produce, and the income taxes are captured in the US.
  - ericd 11y ago
    True. I don't subscribe to the idea that salaries are proportional to the value they create, though. Anyway, there are arguments to be made on both sides, and it's clearly not working very well.