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By: zotdoc Thu, 23 May 2013 20:58:00 +0000 apple aparently did not break any laws, or they would be facing charges. Congress writes the laws and if they don’t get enough revenue they should re write them. Since congress has written the laws allowing many of us to pay no income taxes at all and those folks get to vote just like I do then, it is my duty as a husband and father to follow the law and take any and all deductions etc that I lawfully can,paying what I owe and not a penny more. congress should enact a flat tax so that we would all have skin in the game.

By: realist50 Thu, 23 May 2013 05:23:13 +0000 I would like to see a move toward requiring formulary apportionment of worldwide consolidated income. Basic concept is apportionment of worldwide consolidated income based on a formula – typically a combination of sales, payroll, and property. (IP transfers could be a sticking point, but maybe just ignore it. Most internally developed IP isn’t capitalized for tax purposes anyway.) pportionment

It would require rewriting tax treaties, but I think any significant overhaul of the tax treatment of international transactions will require rewrites. It’s a concept that is used by many U.S. states for state corporate income tax, so the concept is well-developed and has previously been proposed for international taxation also. I see 2 key selling points.

First, it taxes consolidated income, so we do away with the impact of transfer pricing. Transfer pricing is the central issue in huge amounts of tax minimization/avoidance strategies – be that the example of Apple in this case, Starbucks/Google/Amazon in the UK, etc.

For tech, pharma, or branded firms, there’s the question of where patents and trademarks (IP) are located and at what value they are transferred. Those values by definition are highly subjective. Apple’s transfer technique is arguably more objective than many – fund x% of R&D for an x% stake in its benefits – but is still used to game the system. For an example of how tough it is to assign value except retroactively, how would one have valued Apple’s iPhone-related IP in 2007? How about the value of Blackberry’s IP in 2007? Subsequent events give us an answer that was far from obvious at the time.

Even on a physical good, there’s still plenty of scope to manipulate transfer pricing. It sounds like Apple does so with its retail arm. Starbucks does so with its roasted coffee beans. Any multinational manufacturer that produces its own intermediate goods in different countries – think Toyota, Caterpillar, or GE – has plenty of scope to argue for a transfer price anywhere between production cost and sucking all the profit out of the final assembled product.

Worldwide apportionment also provides the capital flow benefits of a territorial system – all income is by definition assigned somewhere, so there’s no argument to taxing cash when it’s moved between countries. It starts with a sound theory of taxation – a corporation should be taxed on income where its activities occur – and applies a reasonable methodology to apportion that activity.

By: dtc Thu, 23 May 2013 01:50:09 +0000 >in our nation 150 million people manage to avoid personal income taxes<

Indeed. If this isn’t a call to repeal the onerous laws that harm employers seeking to give the 54 million people between 0-12 years of age jobs (rugs, fireworks, etc), I don’t know what is!

But going back to the post – Tim Cook is right. In his testimony, corporate taxes in America must go down to single digits.

The only way we will be competitive is if we bring the tax down to a single digit like -9%.

That’s right… we should start rebating money back to our corporations from people – because corporations are people.

This is a tried and tested way to boost economies – just look at how well our states perform when they compete with each other to give out millions of dollars in hand outs. Oh wait what? Those companies usually move back to their original location afterward? Or don’t deliver the jobs promised? Or build highly automated facilities that requires just 50 people to operate? Well, this time it’s different.

By: Dollared Wed, 22 May 2013 21:45:25 +0000 February22, let Apple leave. They can’t. They owe their life and success to the US, and they can’t function without being headquartered here. And no, they don’t make decisions about where to operate based on taxes. They can start paying taxes in good faith.

If you read the goddamn post, they are hiding US income via their shelters, based on their ridiculous IP pricing scheme.

Nothing went over Senator Levin’s head. The sad part is your licking the balls of a $300B multinational, because, well, I dunno, you tell us why.

By: MyLord Wed, 22 May 2013 21:18:32 +0000 I wondered why Tim Cook didn’t take credit for writing the laws. The committee was probably happy he didn’t thank each of them personally making it all possible.

By: February22 Wed, 22 May 2013 17:54:08 +0000 The point that was made by many (both witnesses and committee members) at yesterday’s witch hunt… er, I mean hearing, was that by making tax laws less complex and more competitive with other countries, American corporations (like Apple) would be more inclined to repatriate foreign funds, and invest that money in the USA rather than in foreign countries.

In other words, forcing companies to pay higher taxes at home is chasing business investments and employment to other countries.

A company’s financial responsibilities are to its share holders… Not to the government.

By making tax laws less complex, and by lowering corporate taxes so that they are inline with taxes in other jurisdictions, those large corporations would end up moving more investments home, resulting in them paying more taxes in the USA and also employing more people there.

It’s a very simple to understand concept, that apparently went over Senator Levin’s head.