[AnthonyMouse]

I'm not sure what line you're attempting to draw. An accountant's job isn't just to make sure you file the right paperwork, it's to identify courses of action that could have a significant effect on the bottom line. You seem to be suggesting that a business would be doing something unreasonable by moving any of its operations into a jurisdiction with lower taxes, since that would be making an investment in order to pay less taxes.

[skore]

> You seem to be suggesting that a business would be doing something unreasonable by moving any of its operations into a jurisdiction with lower taxes [...]

Moving to or setting up a subsidiary in a different jurisdiction: Completely fine.

Doing the same thing for the sole purpose of avoiding taxes: Not fine.

I really don't get what's so hard to understand about that. How many employees do Google or Apple have in Ireland, the Cayman Islands or the Netherlands? And how many in the US? Quite simple, I think.

[AnthonyMouse]

>Moving to or setting up a subsidiary in a different jurisdiction: Completely fine.

>Doing the same thing for the sole purpose of avoiding taxes: Not fine.

And how exactly do you propose to distinguish the two?

"Number of employees" is a completely worthless metric. Apple (and/or Foxconn) employs many times more employees in China than in the U.S., does that mean they should be reporting most of their profits in China?

[skore]

I'm pretty sure that Foxconn and Apple are separate corporations, so I have no idea what you're getting at.

Apple has 73k employees, 50k of which are in the US. Pretty sure most of them have benefited from US society (education, roads, police stations etc.) or benefit from it now that they have moved to the US.

[AnthonyMouse]

>I'm pretty sure that Foxconn and Apple are separate corporations, so I have no idea what you're getting at.

Apple US is a separate corporation from Apple China too, that's how all of this works. Apple Ireland ends up with all the profits and is a distinct corporate entity from Apple US.

You keep talking about use of government services or where employees are. Those things are not corporate profit. If you want to tax companies that employ your workforce then you can tax payroll. If you want to tax companies that use local government services then you can tax commercial real estate. What you can't do is try to tax corporate profit at one of the highest nominal rates in the world and then be surprised when international corporations arrange to stop reporting any profits within your jurisdiction. Profit is a highly mobile asset. It's like trying to levy a local property tax on gold bullion -- the people who own large amounts of bullion are just going to move it out of your tax jurisdiction. If you then say "but they still live here and use government services" they're just going to shrug and look at you like you're a crazy person for expecting anything different to have happened, because you're trying to tax the wrong thing.

[skore]

Sheesh.

Foxconn wasn't build as a subsidiary of Apple. Not sure what you're getting at with that. Yes, I understand the technicalities, but if it didn't happen that way and the intent of how it happens is the way it is, arguing the permutations is a strawman.

> You keep talking about use of government services or where employees are. Those things are not corporate profit.

Yes and no. Those government services are not corporate profit, sure. But they are what makes the Apple corporation possible in the first place. Apple wasn't founded in Ireland, the Netherlands and certainly not on the Cayman Islands. The "thank you" payment for that is called taxes.

> they're just going to shrug and look at you like you're a crazy person for expecting anything different to have happened

Yup, that's what I would call destructive attitude. A society works because a sufficient number of people think it's a good idea to make it work. Large corporations are simply lucky to get away with behaving differently, for profit. If a majority of people were behaving like that - cutting around the system at every chance they get while obscuring their tracks with money, for their own benefit - you end up with no society at all very quickly.

Put differently: large corporations should count themselves lucky that there are enough reasonable people (the lower and middle class suckers who are constantly being degraded to a purer form of worker drone consumers) to offset the damage that they do.

All laws have to assume to a varying extent that people are interested in the society they live in. Because if they aren't, no law whatsoever is going to make them a good member of society. Kind of like how the DSM-IV has no definition of psychopathy because it describes the absence of a mind capable of having a disorder in the first place. The way those large corporations behave is truly antisocial behavior, lacking regard for the deeper and finer points of how society works.

> because you're trying to tax the wrong thing

Funny, because to me it seems that no matter what you tax, people who don't want to pay taxes will either seek and find or invest and create a way around that.

This isn't a law problem, it's a culture problem. But I suppose you're right, no sense in arguing culture and civil responsibility with people who lack both.

[cardine]

What is wrong with looking out for you own self interests?

[AnthonyMouse]

>Foxconn wasn't build as a subsidiary of Apple. Not sure what you're getting at with that. Yes, I understand the technicalities, but if it didn't happen that way and the intent of how it happens is the way it is, arguing the permutations is a strawman.

It isn't a strawman because if you change the rules to make it matter whether one company is a subsidiary of another, they'll just rearrange things so that they aren't. Nothing says Apple Ireland can't be the sole entity the Apple shareholders own, which licenses and sells its products to independent distributors in the United States which Apple Ireland controls under contract, and contracts with other independent U.S. companies to design its products. These companies would then be independent at least to the extent Foxconn is but would have no power (and thus tiny margins) because Apple is the one with the copyrights, the brand and the pile of cash, and they could easily replace those components of their supply chain with competing independent corporations and still hire from the same employee pool and sell to the same customers. Because you're trying to tax profit, which is mobile, instead of the actual things your jurisdiction offers, like a skilled labor force or a large customer base.

>Yes and no. Those government services are not corporate profit, sure. But they are what makes the Apple corporation possible in the first place. Apple wasn't founded in Ireland, the Netherlands and certainly not on the Cayman Islands. The "thank you" payment for that is called taxes.

You keep talking about morality. What law do you propose to cause this to happen? Or are you expecting it to just happen voluntarily if you ask nicely enough?

>All laws have to assume to a varying extent that people are interested in the society they live in. Because if they aren't, no law whatsoever is going to make them a good member of society.

If they aren't then the right law will either change their behavior or put them in prison.

>Funny, because to me it seems that no matter what you tax, people who don't want to pay taxes will either seek and find or invest and create a way around that.

Nonsense. Unless a company is willing to stop owning property or employing workers or selling to customers in your jurisdiction, they can't avoid property tax, payroll tax or sales tax. The problem with taxing "profit" is that they can keep doing everything they were doing before and just shuffle some papers around so that the subsidiary in a low tax jurisdiction is the one making all the money. That's just the nature of profit -- it isn't like a building or an employee or a customer that actually physically exists somewhere.

You're talking about culture and civil responsibility in the context of corporations that compete with one another. A corporation that pays a significant portion of its profits in taxes that it isn't legally obligated to and that its competitors are not doing is going to be at a serious disadvantage.

Simple math. Two competitors each make 20% of their market cap in profit every year and reinvest it. One of them pays no tax, the other pays 40%, so that it grows at 12% instead of 20%. In two decades the company paying no tax is ~38 times bigger, the company paying tax is ~10 times bigger. If they each started out the same size, the company paying no tax will now have ~4 times the cash reserves, which means the company paying taxes is likely to go out of business as soon as the company not paying taxes realizes it will be the sole survivor in a price war. So unless all corporations are good citizens, the ones that are will be destroyed in the market by the ones that aren't.

Which means that the solution has to be to force them to all be good citizens, i.e. to adopt taxes they can't avoid, not to appeal to the corporations to voluntarily commit suicide by doing the right thing unilaterally when no one else is doing it.

[pvnick]

You're overcomplicating the issue. It's not the accountant's job to make up for lazy lawmaking. It's the lawmakers. Go bug the lawmakers, not the people trying to make money within the law.

Would you seriously have done differently in Google's shoes if it meant the difference between millions of dollars? Billions of dollars? Your answer to that question is probably why you're not making those kinds of decisions.

[skore]

Well, I suppose I can only quote Larry Page on this:

--- --- --- ---

He also noted that he has also been sad with how the industry has been unable to advance the Web as quickly as it could have because of a focus on negativity and zero sum gains. He also noted other companies like Oracle and his difficulty in working with them, “Money is more important to them than collaboration.”

--- --- --- ---

As for your feeble attempt at diverting on the law issue: Look, Apple has more cash reserves than the US government. To act as though all that is needed is lawmakers "finally doing their job right" is ludicrous. The reason why I cannot go bug the lawmakers is because they have dozens of lobbyist per capita throwing money into their faces all day long.

At the end of the day, I believe in human progress. Human progress happens when we are fair and kind to one another. Apple doesn't need all of that money, just as Google doesn't need all of theirs. Asking them to give a tiny bit more back to the society that they are a powerful member of so that everybody is better of is far from being as silly as you try to paint it.

[cardine]

Who cares what Apple needs? Consumers voluntarily gave Apple that money and they should have the right to do whatever they want with it and not have to worry about the government arbitrarily stealing it from them in the name of fairness.