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#101
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEO isn't wearing jeans here!!
On Sat, 31 Oct 2015 18:59:18 -0400, Tony Cooper
wrote: On Sun, 01 Nov 2015 10:59:26 +1300, Eric Stevens wrote: On Sat, 31 Oct 2015 09:24:28 +0000, sid wrote: Eric Stevens wrote: 2% is next to zero when you compare it to the 35% they should be paying in the US. You'll have to remind me of your answer to the question as you appear to have written it in invisible ink. But why should they be paying tax in the US? Do they not make any profits in the US? Yes, and they also have expenses in the US. And they do pay tax in the US. They didn't make their products in the US. There are no Apple factories in the US? There are some, but they are also made in China, Ireland and various parts of Europe. They didn't make their profits in the US. What, none of them? The profits on which they don't pay tax in the US are not made in the US. Wait a minute. If Apple makes a device in China, or has a device made in China, brings that device into this country, and sells that device, that revenue becomes part of their taxable income in the US. It doesn't make any difference if the device is manufactured in the US or in China if it's sold in the US by Apple. True, but if China's taxes are lower, I bet that products made in China will be sold on to the US organisation at a premium price. Further, a considerable volume of the products made in China will be sold (and generate profits) in countries other than the US. It is these products not made in the US and not sold in the US of which I said "The profits on which they don't pay tax in the US are not made in the US." -- Regards, Eric Stevens |
#102
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEOisn't wearing jeans here!!
On 10/31/2015 6:59 PM, Tony Cooper wrote:
snip It doesn't make any difference if the device is manufactured in the US or in China if it's sold in the US by Apple. Too simplistic, If a US based company has a widget manufactured in China and sold in Japan for a gain, some portion of the gain on that sale will be taxable in the US. The trick is to allocate as much of the gain as possible to lower tax jurisdictions. The above is much easier said than done. To properly advise a client, the individual, in addition to understanding the client's business, the tax Code and regulations in every jurisdiction in which the client does business, he must have a good working knowledge of the tax treaties in effect and each jurisdiction's interpretation of its own code and the applicable treaties. -- PeterN |
#103
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEO isn't wearing jeans here!!
On 2015-11-01 00:09:56 +0000, PeterN said:
On 10/31/2015 6:59 PM, Tony Cooper wrote: snip It doesn't make any difference if the device is manufactured in the US or in China if it's sold in the US by Apple. Too simplistic, If a US based company has a widget manufactured in China and sold in Japan for a gain, some portion of the gain on that sale will be taxable in the US. The trick is to allocate as much of the gain as possible to lower tax jurisdictions. The above is much easier said than done. To properly advise a client, the individual, in addition to understanding the client's business, the tax Code and regulations in every jurisdiction in which the client does business, he must have a good working knowledge of the tax treaties in effect and each jurisdiction's interpretation of its own code and the applicable treaties. How about when a US customer such as Verizon buys Apple products manufactured in China, and which are delivered directly to Verizon from China. Is the profit reflected on the Apple China books, and not taxable in the US, or does Apple Cupertino act as a broker between Apple China and Verizon reflecting another trade step taxable by the Feds? Would the dealings between the Asian Apple and Cupertino be an internal accounting transaction, or or would there be a taxable profit calculated for Cupertino? This all seems somewhat Byzantine. -- Regards, Savageduck |
#104
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEO isn't wearing jeans here!!
On Sat, 31 Oct 2015 23:15:57 +0000, sid wrote:
Eric Stevens wrote: They haven't moved their profits to the US. As for the 2%, Ireland is free to set whatever tax rate they like. Well there's the thing, Ireland are not free to to give state aid to companies, it's against the law. Whose law? EU You have to realise that the world is a hell of a lot bigger than the USA. check the time zone I post from. Your header is: -------------------------------------------- Path: not-for-mail Content-Type: text/plain; charset="ISO-8859-1" Message-ID: From: sid User-Agent: KNode/4.14.5 Content-Transfer-Encoding: 7Bit Subject: Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEO isn't wearing jeans here!! Newsgroups: rec.photo.digital References: Lines: 19 MIME-Version: 1.0 NNTP-Posting-Host: 82.14.96.137 X-Complaints-To: http://netreport.virginmedia.com X-Trace: 1446333358 82.14.96.137 (Sat, 31 Oct 2015 23:15:58 UTC) NNTP-Posting-Date: Sat, 31 Oct 2015 23:15:58 UTC Organization: virginmedia.com Date: Sat, 31 Oct 2015 23:15:57 +0000 X-Received-Body-CRC: 1155285146 X-Received-Bytes: 1905 ---------------------------------------------- I may be dumb, but I can't see how to work out your time zone from that. What am I missing? -- Regards, Eric Stevens |
#105
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEO isn't wearing jeans here!!
Eric Stevens wrote:
On Sat, 31 Oct 2015 23:15:57 +0000, sid wrote: Eric Stevens wrote: They haven't moved their profits to the US. As for the 2%, Ireland is free to set whatever tax rate they like. Well there's the thing, Ireland are not free to to give state aid to companies, it's against the law. Whose law? EU You have to realise that the world is a hell of a lot bigger than the USA. check the time zone I post from. Your header is: -------------------------------------------- Path: not-for-mail Content-Type: text/plain; charset="ISO-8859-1" Message-ID: From: sid X-Trace: 1446333358 82.14.96.137 (Sat, 31 Oct 2015 23:15:58 UTC) NNTP-Posting-Date: Sat, 31 Oct 2015 23:15:58 UTC Date: Sat, 31 Oct 2015 23:15:57 +0000 ---------------------------------------------- I may be dumb, but I can't see how to work out your time zone from that. What am I missing? There, I've removed a few lines above to make it a bit clearer. -- sid |
#106
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEOisn't wearing jeans here!!
On 10/31/2015 8:26 PM, Savageduck wrote:
On 2015-11-01 00:09:56 +0000, PeterN said: On 10/31/2015 6:59 PM, Tony Cooper wrote: snip It doesn't make any difference if the device is manufactured in the US or in China if it's sold in the US by Apple. Too simplistic, If a US based company has a widget manufactured in China and sold in Japan for a gain, some portion of the gain on that sale will be taxable in the US. The trick is to allocate as much of the gain as possible to lower tax jurisdictions. The above is much easier said than done. To properly advise a client, the individual, in addition to understanding the client's business, the tax Code and regulations in every jurisdiction in which the client does business, he must have a good working knowledge of the tax treaties in effect and each jurisdiction's interpretation of its own code and the applicable treaties. How about when a US customer such as Verizon buys Apple products manufactured in China, and which are delivered directly to Verizon from China. Is the profit reflected on the Apple China books, and not taxable in the US, or does Apple Cupertino act as a broker between Apple China and Verizon reflecting another trade step taxable by the Feds? Would the dealings between the Asian Apple and Cupertino be an internal accounting transaction, or or would there be a taxable profit calculated for Cupertino? The short answer is that Apple China's profit is not fully taxable in the US. It may or may not be partially taxable in the US. Here is a 29 page guide to the issues and resources involved in answering your question. NB Not included is the private letter rulings. (A PLR only affects the applicant. No other entity may rely on it.) I used to do the US-international tax work for a Swiss company, privately held by German nationals, that sold products manufactured in Germany, from components made of materials supplied by wholly and partially owned subsidiaries located in three different countries. These German manufactured products were sold in the US through a wholly owned US subsidiary. All service marks and patents were owned by the German nationals through a separate, wholly owned entity, located in a tax free jurisdiction. I should add that the partially owned subsidiaries mentioned above were in reality wholly owned. The partial ownership was only to comply with the laws of other jurisdictions, restricting non-resident ownership. This all seems somewhat Byzantine. I would have said bizarre. -- PeterN |
#107
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEOisn't wearing jeans here!!
On 10/31/2015 9:22 PM, Tony Cooper wrote:
On Sat, 31 Oct 2015 20:09:56 -0400, PeterN wrote: On 10/31/2015 6:59 PM, Tony Cooper wrote: snip It doesn't make any difference if the device is manufactured in the US or in China if it's sold in the US by Apple. Too simplistic, If a US based company has a widget manufactured in China and sold in Japan for a gain, some portion of the gain on that sale will be taxable in the US. The trick is to allocate as much of the gain as possible to lower tax jurisdictions. Wouldn't that depend on the corporate structure of the seller? Let's say American Widget, Inc, a Delaware corporation, wants to make a product in China and sell it in Japan. I would think, then, that American Widget, Inc would then create a corporation based in some other country with a favorable tax structure to do this. It would be something like American Widget (Macau),LLC. It wouldn't make sense to have the parent company doing it. Yep! That's why we have transfer pricing rules, an why I said your original statement was too simplistic. -- PeterN |
#108
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEOisn't wearing jeans here!!
On 11/1/2015 11:12 AM, PeterN wrote:
On 10/31/2015 8:26 PM, Savageduck wrote: On 2015-11-01 00:09:56 +0000, PeterN said: On 10/31/2015 6:59 PM, Tony Cooper wrote: snip It doesn't make any difference if the device is manufactured in the US or in China if it's sold in the US by Apple. Too simplistic, If a US based company has a widget manufactured in China and sold in Japan for a gain, some portion of the gain on that sale will be taxable in the US. The trick is to allocate as much of the gain as possible to lower tax jurisdictions. The above is much easier said than done. To properly advise a client, the individual, in addition to understanding the client's business, the tax Code and regulations in every jurisdiction in which the client does business, he must have a good working knowledge of the tax treaties in effect and each jurisdiction's interpretation of its own code and the applicable treaties. How about when a US customer such as Verizon buys Apple products manufactured in China, and which are delivered directly to Verizon from China. Is the profit reflected on the Apple China books, and not taxable in the US, or does Apple Cupertino act as a broker between Apple China and Verizon reflecting another trade step taxable by the Feds? Would the dealings between the Asian Apple and Cupertino be an internal accounting transaction, or or would there be a taxable profit calculated for Cupertino? The short answer is that Apple China's profit is not fully taxable in the US. It may or may not be partially taxable in the US. Here is a 29 page guide to the issues and resources involved in answering your question. NB Not included is the private letter rulings. (A PLR only affects the applicant. No other entity may rely on it.) I used to do the US-international tax work for a Swiss company, privately held by German nationals, that sold products manufactured in Germany, from components made of materials supplied by wholly and partially owned subsidiaries located in three different countries. These German manufactured products were sold in the US through a wholly owned US subsidiary. All service marks and patents were owned by the German nationals through a separate, wholly owned entity, located in a tax free jurisdiction. I should add that the partially owned subsidiaries mentioned above were in reality wholly owned. The partial ownership was only to comply with the laws of other jurisdictions, restricting non-resident ownership. This all seems somewhat Byzantine. I would have said bizarre. I forgot to include the link. https://www.irs.gov/pub/int_practice_units/ISO9411_02_01.pdf -- PeterN |
#109
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEO isn't wearing jeans here!!
On Sun, 01 Nov 2015 08:50:16 +0000, sid wrote:
Eric Stevens wrote: On Sat, 31 Oct 2015 23:15:57 +0000, sid wrote: Eric Stevens wrote: They haven't moved their profits to the US. As for the 2%, Ireland is free to set whatever tax rate they like. Well there's the thing, Ireland are not free to to give state aid to companies, it's against the law. Whose law? EU You have to realise that the world is a hell of a lot bigger than the USA. check the time zone I post from. Your header is: -------------------------------------------- Path: not-for-mail Content-Type: text/plain; charset="ISO-8859-1" Message-ID: From: sid X-Trace: 1446333358 82.14.96.137 (Sat, 31 Oct 2015 23:15:58 UTC) NNTP-Posting-Date: Sat, 31 Oct 2015 23:15:58 UTC Date: Sat, 31 Oct 2015 23:15:57 +0000 ---------------------------------------------- I may be dumb, but I can't see how to work out your time zone from that. What am I missing? There, I've removed a few lines above to make it a bit clearer. Yes, I have studied the date and time information but came to no definitively useful conclusion. How about an explanation? -- Regards, Eric Stevens |
#110
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Apple may owe Ireland 10 YEARS of back-taxes. Notice dickhead CEO isn't wearing jeans here!!
On 2015-11-01 19:48:26 +0000, Eric Stevens said:
On Sun, 01 Nov 2015 08:50:16 +0000, sid wrote: Eric Stevens wrote: On Sat, 31 Oct 2015 23:15:57 +0000, sid wrote: Eric Stevens wrote: They haven't moved their profits to the US. As for the 2%, Ireland is free to set whatever tax rate they like. Well there's the thing, Ireland are not free to to give state aid to companies, it's against the law. Whose law? EU You have to realise that the world is a hell of a lot bigger than the USA. check the time zone I post from. Your header is: -------------------------------------------- Path: not-for-mail Content-Type: text/plain; charset="ISO-8859-1" Message-ID: From: sid X-Trace: 1446333358 82.14.96.137 (Sat, 31 Oct 2015 23:15:58 UTC) NNTP-Posting-Date: Sat, 31 Oct 2015 23:15:58 UTC Date: Sat, 31 Oct 2015 23:15:57 +0000 ---------------------------------------------- I may be dumb, but I can't see how to work out your time zone from that. What am I missing? There, I've removed a few lines above to make it a bit clearer. Yes, I have studied the date and time information but came to no definitively useful conclusion. How about an explanation? I think the answer is, neither one of you lives in the USA, or is a US citizen, and familiarity with the US tax code for both of you is based on online reading, hearsay, and speculation. -- Regards, Savageduck |
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