4 ms·

>Incorrect. There is a repatriation tax holiday designed to encourage repatriation. They are not required to do so. Unfortunately, you're incorrect. https://w

by IBM 9y ago

>Incorrect. There is a repatriation tax holiday designed to encourage repatriation. They are not required to do so. Unfortunately, you're incorrect. https://www.pwc.com/us/en/tax-services/publications/insights/tax-reform-readiness-us-mandatory-deemed-repatriation-issues.html https://www.pwc.com/us/en/tax-services/publications/insights...

hateduser2 9y ago
No u
- dang 9y ago
  Would you please not post unsubstantive comments here?
downandout 9y ago
Unfortunately, that article is clear as mud and seems to use the word “mandatory” in its headline as editorialized clickbait. In its explanation: “[The plan] uses the mechanics under subpart F to impose a one-time ‘toll charge’ on the undistributed, non-previously taxed post-1986 foreign E&P of certain US-owned foreign corporations as part of the transition to a new territorial regime. The toll charge is reduced by a deduction computed in a manner that ensures a 15.5-percent effective tax rate on ‘cash’ and an 8-percent effective tax rate to the extent the inclusion exceeds the cash position.” There is nothing there indicating that people with guns were going to show up with guns and demand that Apple repatriate its cash. Once again, the bill was designed to encourage repatriation.
- IBM 9y ago
  I'm not sure why you think a big 4 accounting firm would need to do clickbait, but that's beside the point. Whether Apple left the cash in Ireland or brought it back to the US, they would have paid $38B in taxes. That's the mandatory part. That's what the quoted text literally says. And since you seem to be unaware, the vast majority of Apple's cash has already been in the US for years, invested in US treasuries and other fixed income assets and held by American trust banks. It's Irish cash only in a legal sense. This is broadly true for all other American multinationals as well.
  - downandout 9y ago
    The point is that the tax is mandatory, not the repatriation. If they didn’t believe that the US was the best place to put that money, they could have paid the tax and left it there or moved it elsewhere. The fact that they are deploying that capital here indicates some level of belief that the American economy will thrive under this tax plan.
    - threeseed 9y ago
      This is pure fiction you've invented here. Apple bringing capital back to the US is solely to do with their being tax incentives to do so. Nothing more. Nothing less.
      - downandout 9y ago
        As you said, they are being incentivized to do so. It isn’t mandatory, which is what this whole argument is about. I don’t know how it’s “pure fiction” to point that out, when your own comment literally says what I have been saying.
        threeseed 9y ago
        > The fact that they are deploying that capital here indicates some level of belief that the American economy will thrive under this tax plan. This statement is fiction. There is nothing from Apple indicating this.
        downandout 9y ago
        They are indicating it by doing it. That cash doesn't have to remain here; they simply have to pay taxes on it. The only reason that a rational corporation would keep it here is because they believe it's a good investment.
        m52go 9y ago
        Sorry you keep getting hassled for such a simple point. The tax is being levied on all overseas money (mandatory) and some companies are deciding to bring that money back to the USA (voluntary). Not sure what's so hard to understand about that.
prklmn 9y ago
Disregard the link with the confusing title and think critically for a moment. Do you really think the US government is forcing all companies to bring any and all profits earned and stored overseas back to the United States? That’s what you’re implying.
- IBM 9y ago
  The US government is forcing all companies to pay a mandatory tax of 15.5% on all overseas profit that was designated as "indefinitely reinvested" under the previous tax regime. This is a mandatory one-time tax as part of a shift to a territorial system. Multinationals can do whatever they want with the cash, but considering that they've been lobbying government on a repatriation bill for over a decade specifically to be able to do domestic M&A, pay dividends, or do share buybacks, it's pretty obvious that all of that cash is coming back to the US. A business that wants to reinvest all their cash internationally is free to do so (and in fact the previous tax regime incentivized it), but they're going to be paying US tax on what they've accumulated so far.
- pdeuchler 9y ago
  Where the database that holds the dollar amount is located doesn't matter, what matters is where it's taxed and where it's spent. The US government _forced_ the companies to pay this tax, that point is irrefutable.
  - downandout 9y ago
    All taxes are compulsory - "_forced_" - as you put it. Who would pay them if they weren't? However, they are free to invest it wherever they choose, and they have chosen the US. That is not "mandatory repatriation".

by IBM 9y ago

hateduser2 9y ago

No u

dang 9y ago
Would you please not post unsubstantive comments here?

downandout 9y ago

Unfortunately, that article is clear as mud and seems to use the word “mandatory” in its headline as editorialized clickbait. In its explanation: “[The plan] uses the mechanics under subpart F to impose a one-time ‘toll charge’ on the undistributed, non-previously taxed post-1986 foreign E&P of certain US-owned foreign corporations as part of the transition to a new territorial regime. The toll charge is reduced by a deduction computed in a manner that ensures a 15.5-percent effective tax rate on ‘cash’ and an 8-percent effective tax rate to the extent the inclusion exceeds the cash position.” There is nothing there indicating that people with guns were going to show up with guns and demand that Apple repatriate its cash. Once again, the bill was designed to encourage repatriation.

IBM 9y ago
I'm not sure why you think a big 4 accounting firm would need to do clickbait, but that's beside the point. Whether Apple left the cash in Ireland or brought it back to the US, they would have paid $38B in taxes. That's the mandatory part. That's what the quoted text literally says. And since you seem to be unaware, the vast majority of Apple's cash has already been in the US for years, invested in US treasuries and other fixed income assets and held by American trust banks. It's Irish cash only in a legal sense. This is broadly true for all other American multinationals as well.
- downandout 9y ago
  The point is that the tax is mandatory, not the repatriation. If they didn’t believe that the US was the best place to put that money, they could have paid the tax and left it there or moved it elsewhere. The fact that they are deploying that capital here indicates some level of belief that the American economy will thrive under this tax plan.
  - threeseed 9y ago
    This is pure fiction you've invented here. Apple bringing capital back to the US is solely to do with their being tax incentives to do so. Nothing more. Nothing less.
    - downandout 9y ago
      As you said, they are being incentivized to do so. It isn’t mandatory, which is what this whole argument is about. I don’t know how it’s “pure fiction” to point that out, when your own comment literally says what I have been saying.
      - threeseed 9y ago
        > The fact that they are deploying that capital here indicates some level of belief that the American economy will thrive under this tax plan. This statement is fiction. There is nothing from Apple indicating this.
        downandout 9y ago
        They are indicating it by doing it. That cash doesn't have to remain here; they simply have to pay taxes on it. The only reason that a rational corporation would keep it here is because they believe it's a good investment.
        m52go 9y ago
        Sorry you keep getting hassled for such a simple point. The tax is being levied on all overseas money (mandatory) and some companies are deciding to bring that money back to the USA (voluntary). Not sure what's so hard to understand about that.

prklmn 9y ago

Disregard the link with the confusing title and think critically for a moment. Do you really think the US government is forcing all companies to bring any and all profits earned and stored overseas back to the United States? That’s what you’re implying.

IBM 9y ago
The US government is forcing all companies to pay a mandatory tax of 15.5% on all overseas profit that was designated as "indefinitely reinvested" under the previous tax regime. This is a mandatory one-time tax as part of a shift to a territorial system. Multinationals can do whatever they want with the cash, but considering that they've been lobbying government on a repatriation bill for over a decade specifically to be able to do domestic M&A, pay dividends, or do share buybacks, it's pretty obvious that all of that cash is coming back to the US. A business that wants to reinvest all their cash internationally is free to do so (and in fact the previous tax regime incentivized it), but they're going to be paying US tax on what they've accumulated so far.
pdeuchler 9y ago
Where the database that holds the dollar amount is located doesn't matter, what matters is where it's taxed and where it's spent. The US government _forced_ the companies to pay this tax, that point is irrefutable.
- downandout 9y ago
  All taxes are compulsory - "_forced_" - as you put it. Who would pay them if they weren't? However, they are free to invest it wherever they choose, and they have chosen the US. That is not "mandatory repatriation".