496 posts • joined 12 Feb 2008
This is sadly wrong.
"This is because ASI and its parent, Apple Operations International, manage to fall between US and Irish tax law: America doesn't tax the operations because they're not US-registered; Ireland winks at them because they're managed in the US."
Those profits are indeed taxable in the US. But only if they are actually taken into the US. Because that's what US tax law says: foreign profits are taxed only if they are moved into the US.
This is why Apple has vast cash piles outside the US yet borrows money inside it to pay dividends and fund stock buybacks. Because it doesn't want to take those foreign profits in and then pay US tax.
This all might be a good idea or a bad one. But it is the way that it is and those Oz, "experts" really ought to try and understand what is going on before they pronounce.
This paper is very simple indeed
It's true that crime goes up as temperatures in a given location do. More people outside running around for a start. Anyway, it's a well know correlation. However, from the paper itself:
"However, there is no obvious
cross-sectional relationship between the temperature zones and crime rates."
There is no relationship at all between generally higher temperatures in any location and the crime rate.
If climate change means that we get greater variance of temperature in each place then this guy's calculation could be right (please note "could"). But as the contention is that average temperatures will increase everywhere he's not. Because changes in average temp don't change crime rates, it's variance in temp that does.
"I would rather prefer to be a horse than a bull in my next life."
Why not try to come back as an upper class Englishman? Much the same, you'll be shagging mares most of your life.....
"Why is it astonishing that Forbes staff used forbes(xxxx) as a password? I would actually be shocked if that wasn't the case."
You'd be even less shocked if you knew the format of the password that was assigned to you when you first had a contributor account set up.....
Re: So is this the end for.....
Fairphone is trying to do something a little different.
They want to use the minerals from the area but only non-bandit ones. Everyone else is trying to make sure they do not use bandit ones. So Fairphone are deliberately going into the area (or their proxies etc are) acquiring local but non bandit ores to process.
So instead of a phone that doesn't use bandit stuff, we've a phone that is non-bandit but is also helping the legitimate artisanal miners in the area.
In the long run this will increase the difference in price between bandit and non-bandit ores which would be a good thing. It will increase the incentive to mine i a non-bandit manner in the area.
I've no idea whether it will work but happy to give them credit for the attempt.
Re: Haven't these people heard of the division and specialisation of labour?
Sure, I was talking about what it was compulsory for children to be taught, not what people might want to learn on their own.
Haven't these people heard of the division and specialisation of labour?
We no more want everyone to be able to code than we do want everyone to know how to fly a plane or build a house.
There are some skills that we'd like pretty much everyone to have, yes. Literacy, numeracy, cooking, drive a car, these sorts of things. But coding just isn't one of them.
To be able to *use* a computer, sure. But not to program one.
In this gap in the timetable they could start teaching kids some economics. But then I would say that of course.,,,,
True story: Roy Hattersley, who was at one time Sec of State for Prices, and at another Shadow Chancellor, was 80 years old before he found out that Adam Smith had written not only Wealth of Nations but also A Theory of Moral Sentiments. At least we could try getting the people who attempt to run the country up to speed on the basics of economics, no?
Someone has read Jaron Lanier and taken him seriously.
Might not have been the very best idea that.
Re: Gotta love this
Well, yeah, but. Rounded corners is a design patent which actually operate much more like copyright/trademarks than patents.
Re: Superb article
Most kind. I'm sure the editor will be taking requests for pay rises soon......
I've since seen that Google is keeping the Project ARA bit. So they may well have an decent argument that they do get to keep those tax losses. They've sold out the assets, not the holding company perhaps?
Re: Labour theory of Value
Yeah, that's one bit of Marx that is wrong unfortunately. It's entirely possible to construct a logical chain where this should be true but it just isn't the way that human beings actually act.
The way we do act is Adam Smith's theory of value: we value things at the value that they give to us. I value a corkscrew rather more highly than my teetotal aunt does for example.
Given that we don't actually value things according to the labour that went into their production we can't then try to plan our value system on that labour. Just doesn't work.
Re: The win-win
That's a pretty good description of the whole shebang there.
Re: How about...
"The UK operation buys ridiculously expensive coffee beans from the Swiss operation"
Hmm. 20% above cost actually. And the cost of beans is a terribly minor one for a coffee shop. Even when you add this 20% back in it doesn't make Starbucks UK make a profit.
And there should be some margin paid to the Swiss trading operation, shouldn't there? They are buying the coffee for all Starbucks across Europe. It is right that there should be a margin on such work? Y/N?
"As for paying to use the Starbucks name, what the f*ck? Starbucks UK is not a franchise,"
Starbucks does have franchises though. And they are charged the same rate that Starbucks UK is charged. And there is a value to being able to use the name, no? We would expect a shop called Starbucks to attract more custom than one called Fred's?
It's also worth noting that EU law actually bans the UK from charging tax on royalty streams going to another company based in the EU. Actually bans it. What's more, HMRC did have a look at the royalty rate and Starbucks lowered it (from 6% or so to 4.5% or so from memory). So it really has been looked at and everyone agrees that the practice is, at least now, just peachy.
Finally, even if you add all of these supposed dodges back in Starbucks UK *still* wasn't making a profit. We've even had Vince Cable stating this (as well as FT Alphaville and a number of accountants of my acquaintance).
Re: Well of course they are
But they're not natural persons: they're legal persons.
What SCOTUS said was that certain constitutional provisions applies to the legal persons that are corporations. Like, for example, free speech (which is where the being able to donate to political campaigns comes from, that's regarded as an expression of free speech).
Certain other constitutional provisions do not apply to the legal persons that are corporations. Cruel and unusual punishment for example.
SCOTUS absolutely did not say that corporations are natural persons. They just defined which constitutional provisions apply to legal persons.
Well of course they are
"corporations are people according to SCOTUS."
A corporation is a legal person. And we're all very glad that they are too. For being a legal person is the definition of us being able to sue them.
If you're not a legal (nor natural) person then you can't commit crimes, sue or be sued. Or be taxed of course.
Given this would you prefer that corporations were not legal people?
Re: A monopoly is all we need
"In this situation a new hold in the ground would allow you to pull out tantalum and sell it at a profit even if the price of tantalum goes down a fair bit."
Hmm, but. There's two extant tantalum mines that are on a care and maintenance basis at present. Tanco and Sons of Gwalia. OK, at least, last time I looked around this market these two extant mines were there, capable of being operated, and weren't being operated.
Given this people just aren't very interested in the idea of new tantalum mines.
"The only reason it doesn't attract investors is because there is a greater profit to be made elsewhere."
Which sounds like an excellent idea really. There's a limited amount of capital in the world, profit is the measure of how much value is being added by deploying that capital. Thus we *want* people to be deploying their capital where it makes the largest profits.
Re: A monopoly is all we need
I'm afraid that there's a problem with this analysis. That being that you almost certainly wouldn't make a profit by mining for rare earths. Because other people have got there first. There's Molycorp, reopened the mine in California. And Lynas with their mine in Oz and processing plant in Malaysia. They're both up and running and production between the two will reach around 40k tonnes a year.
Which is around and about the non-China demand for rare earths anyway.
That sounds like a pretty good reason that people don't want to invest in rare earth mines really.
Quite apart from the fact that there are vastly cheaper places to get them from than by digging another damn hole in the ground. There's large amounts in the wastes from other processes for example: 20,000 tonnes a year in red mud from alumina production alone. And yes, they can be extracted: we've actually done that experiment ourselves. However, with those other people already in the market it's not profitable either....
Interesting....given that the new President of China's "family investment firm" owns a big chunk of the number two RE producer in China.
They've not left a multibillion fab unused. They built the building and then didn't put the fab into it.
Once you've actually built the whole damn thing, Si ingot makers, slicers, etchers and all the rest there's absolutely no way at all that you don't run the thing. For the running costs are entirely spit in relation to the capital costs of having got that far.
And it's all that gear that is "the fab", not the building itself.
Sure, Intel spent good money on the building but it's not multi-billions, no way.
One way of checking this is that if they had they would have already made a release to the SEC stating that they were going to take a multibillion write off of the cost of that plant. Which, at least as far as I know, they haven't. The costs of the walls and ceiling aren't sufficiently large to be relevant to Intel which is why they've not had to announce such a write off.
The above is all speculation BTW but it is how I read this story.
Re: Proof by assertion
Worth noting that fashion is covered by trademark (you can't go around passing stuff off....very like Apple's design patents) and recipes are covered by copyright. "Lemon chicken" ain't copyright but the specific recipe, the words used to explain it, are.
I had a go at this test
And the way to get a fast time is not even read the questions. Just select a as the answer. If it's correct (25% chance) then on to the next. If not, hit b. If not, c and so on.
You get through it in perhaps 30 seconds.
So, fanbois are better at randomly pushing buttons to see what happens next?
Re: Hmm, Lompoc
It's a very old joke, sorry, An adaptation of the one where not drinking won't make you live longer but it will make it seem longer.
A week in Lompoc is so interesting that it seems like a month elsewhere......
The central coast of California is really wonderful.....as is, say, rural Somerset. But Lompoc is a bit like Radstock say./.....
I spent a month there one week. Outside the jail of course but it's one of the few places I've been where inside might be more attractive.
"Your great grandfather's introduction to aviation was something like this"
That was my grandfather's introduction to it. Sopwith Camels, SE5As etc etc...
Not quite. There are versions of both that are TD-SCDMA compatible but not all versions of the two iPhones are so compatible. All are TD-LTE compatible though.
The actual proposal wouldn't have made any difference at all to Google or Facebook. Because it was all about VAT. Which is a tax on consumers, not producers.
Even if it were not found illegal under EU law (as I've been predicting it would be) all Google would need to do is appoint an agent in Rome, give him a 0.5% margin on all sales and still send all the cash to Ireland.
The people who proposed this are simply incompetent.
However they had made provision for a substantial payment in their accounts...
Not quite exactly.
What they did is say that we're going to bring some of these foreign profits into the UK in order to pay dividends to our nice shareholders. And all of us, Vodafone, HMRC, the courts, the EU, agree that when those profits come back into the UK to pay a dividend then corporation tax will be due.
That's actually what they did.
Re: Evolutionary pressures
I believe a better phrase is "winnowing of the weakest"
Yes, I like that. Will use it from now on.
So why not call it DryPhone then?
Driza-bone. Oz company been making waterproofs since 1898.
Riffing off what would be a common identification around the Tasman Sea.
it's not admin costs
Facebook Irish company I did not pay over 1.75 billion in admin costs to Facebook Irish company 2. It was royalties for the use of the Facebook name and technology.
"But the method could soon be stamped out by bringing an end to "stateless companies" in Ireland, it's been reported."
Not so much. It's Apple that has a company with no tax domicile in its Double Irish structure. Facebook does not. Facebook Irish company 2 is tax domiciled in the Caymans. So cracking down on companies with no tax domicile won't make any difference to Facebook.
25 years ago I did some phone work for Dell as a contractor in the UK. And it was exactly the same then.
zzircon....sand, the ore. zirconia, the oxide (which can indeed be made into cute crystals). zirconium, the metal, used for making those fuel rods they're pulling out of Fukushima.
Mebbe......I'm currently trawling the waste ponds of a uranium processor for stuff so city dumps look quite attractive really.
From the paper:
"It thus appears that society will need to pay more attention to
the acquisition and maintenance of nonrenewable resources than
has been the case in the past. Growing populations, growing
affluence, and the materials diversity of modern technologies are
straining the resource capacities on which we draw. The situation
need not inspire panic, but should instead stimulate more diligent
and more comprehensive approaches to the balance between
supply and demand across the entire periodic table."
As above, they don't seem to understand that there isn't any shortage of these various metals or ores so no, we don't have any supply constraints.
My favourite example is from an old story in New Scientist. They stated that world reserves of hafnium would run out in 2017. They entirely failed to understand that we only produce Hf when we want nuclear grade zirconium. So, we end up with some 500 tonnes or so a year of Hf floating around. The other 24,000 tonnes available to us in the non-nuclear grade Zr we use each year is just never processed out. And there's tens of thousands of years' worth of Zr ores floating about.
Re: @Tim @Tim Worstal
The 100,000 comes from the Hyperios guy mentioned in the piece.
"but is there any harm in trying to move, be it so slightly, the bell curve of decency just a touch to the better?"
Yup, great. With two provisos.
1) Needs to be voluntary. You might be willing to spend $32 on this. Many others would not be. Like, for example, that poor woman in Tanzania who is using a $10 feature phone. So, it must indeed be voluntary.
2) It must be efficient. It must solve the problem at the least expenditure of resources possible. Because if we use resources efficiently then we still have resources left over to try and solve other problems at the same time.
Industry initiative is here:
As I propose, concentrating upon the smelters, not all 6,000 listed US companies.
And the reason to use the penny per phone as against the $4 billion? Because it was the penny per phone that was used to sell the idea to us. That's what the Enough Project was saying three and four years back. We can solve this conflict minerals problem for that sum.
Now that it's actually law how much does the SEC tell us it is costing? $4 billion. That's why the two figures are contrasted with each other. One was the number used to sell us the program. The other is the real cost.
Re: Doomed to fail
"And, of course, how long will it take a black-market, illegal, polluting,12th supplier to appear operating inside one of the conflict zones, shipping their product out through a corrupt middleman who relabels it as good?"
Most unlikely to happen with tantalum. It will happen, is happening, with gold. For there are tens of thousands of places around the world where you can turn up with some gold and get paid cash for it. Refining tantalite is a little bit more difficult. You need tanker loads of HF for example. The sort of thing that will immediately kill anyone trying to do anything in a low tech manner.
"By the way, just out of curiosity, what's the value of your life? How much is an equitable amount to ask society to protect it from exploitation, harm and an untimely end?"
The British Government currently values it at £2 and a bit million. Because that's the amount they're willing to spend on, say, preventing a death by increasing the safety measures on the railways.
Of course, the NHS values it rather more lowly. The maximum they'll spend on a treatment to keep me alive for a year, if I were to be struck down by some horrible illness, is £30 k for the drugs. Get a disease that costs more than that and NICE tells us we're shit out of luck.
The bit that you seem to be missing is that our entire society is permeated with these calculations of how much a life is worth. Has to be as well, for without such a calculation we've no idea at all about how to allocate resources. Spend £20 million on saving the darlin' babby from some cancer? Or do 5,000 hip transplants? Which produces greater utility from our scarce resources?
"So just exactly what is the cash sum value of a human life?"
Of one? Impossible to say. The statistical value of a life? Depends upon what value the people in that society put on a life. Usual number for the US is about $5 million, for the UK £2 and a bit million. It's very, very much lower in much poorer countries of course.
No, not because poor people are worth less. But because poor people themselves value their own lives less highly.
For how we work this out is we look at the amount of money people demand for taking certain risks. What is the wage premium for a job that is known to be more dangerous than others for example? From that we work backwards to that statistical valuation of a life. And yes, obviously and clearly poor people will take greater risks for the same amount of money than those of us blessed to be born into a rich country would.
So, that's how we work it out.
"I would surely love it if we could get the kind of international cooperation together required to have all the refineries and all the chip spinners do their part and turn Billions of dollars of regulatory cost into a meager few million in externally-monitored self regulation.
Unfortunately, we have no way to compel many of these companies to agree to such a scheme or to enforce their compliance."
Strange that. For the electronics industry does have a scheme that does exactly this. And it works too: as I predicted some years ago it would. Because it's designed by people who know what the fuck they're doing.
"I will gladly pay an additional $32 per device to ensure my widgets are sourced from conflict-free sources. Frankly, I'm fucking appalled that there are people who wouldn't. I am ashamed to be a member of the same species as those individuals and I consider anyone who finds that "too much to pay" as no different in my mind from the bastards perpetuating these horrific crimes: both groups view the life and suffering of another sapient being as irrelevant to their own selfish, petty desires."
Great, you do so. Others might not share your views so why should they have to pay the price premium you are willing to pay?
And of a great deal more interest of course is that is spending $4 billion this way (recall, it doesn't stop anyone using conflict minerals. It only says that they must say if they are: which isn't going to budge that many consumers in China, is it?) the best way of stopping the problem? Perhaps spending $4 billion on sending the US Marines in to kill the fuckers would work better? Perhaps the $10 million industry plan would work just as well? Which is, of course, why you do cost benefit analyses. So that you can work out what is the best way of doing something.
For of course, if we can solve the problem for $10 million instead of $4 billion then that gives is $3.9 billion to spend on something else. I dunno, and education or health care system for Eastern Congo sounds like a better use of that sort of money that a bureaucratic fucking paper chase, doesn't it?
Re: Doomed to fail
No, no isotopic difference in the Ta. But the various ores all have very different trace elements in them. You can tell where an ore is from by reference to the database of those trace elements (which has been prepared by BGR, the German geological survey. Nice bunch of blokes, have been very helpful to me).
So, given that all 11 of the plants that can process tantalite will be testing their ores (because you pay for the ore on the percentage of Ta contained, meaning that obviously you've got to test it to make sure of that percentage) all we need to do is check that testing against the database......
Re: Usual problem ?
I've had a long conversation with another group in this field who are proposing regulations for the EU along the same lines.
I asked two questions (among many others).
1) What will be thew costs of your proposed regulations?
2) What will be the benefits expressed again as a cash sum?
The response I got was that it wasn't their job to do cost benefit analyses.
It was about then that I started to get very angry with them. WTF do you mean you don't know whether there will be a net benefit from these proposals of yours?
Re: We really need evidence.
"I think it very unlikely that a society *with* patents and copyrights would have a chance competing against a society without them."
We've an interesting example of that going on right now. India almost never observes copyright and China rarely either copyright or patents. They are significantly poorer than we are although growing faster.
The usual economic argument deployed is that a society will ignore foreigners' IP for as long as there's no serious domestic sources wanting to have their own IP protected domestically.
Indeed, I've often argued (elsewhere) that we should simply ignore IP violations in poor countries. No, not on their exports to us, but in their domestic economy? Meh: it's a problem that will solve itself over time. So I'm generally against TRIPS and so on, that tries to enforce IP in trade treaties.
Sightly strange complaint
"A case in point being the US, where the absence of public health-care,"
The US actually spends some 8 or 9 % of GDP on public health care. About the same portion as we were paying on the NHS back in 2001/02 sort of era.
The major complaint in the US is actually that they spend so much tax cash on public health and don't seem to get anything like the NHS for it.
BTW, I'm not a defender of the US health care system as it is, I would certainly recommend radical change in it. Just not in hte direction they are changing it.
The Italians are claiming that the profits in Ireland should be taxed in Italy.
They can claim this all they want. For EU law states that those profits should be taxed in Ireland at whatever rate Ireland decides to tax them.
It's simply nothing at all to do with the Italian tax system.
Mebbe it shouldn't be this way but it is.
One type of lightbulbs already does sometimes. Metal halide bulbs.
Pretty niche but it does happen.
That's an excellent point. Thanks for making it.
Ta v much, most kind of you to say so.
I shall be around the back polishing my ego while on speed dial to El Supremo asking for a pay rise.....
Makes the old mantra seem truer than ever
Never, ever, upgrade to version x.0 of anything at all.
Re: Coding's an essential life skill
" And without understanding some elementary programming principles, you can't do much more in Excel than your daily expenses."
I can't even do that in Excel. Life doesn't seem to have ground to a halt as a result.
What seems to be being missed in general here is the value of the division and specialisation of labour.
It's simply not necessary for everyone to know how to code (or program for those making the distinction) any more than it is for everyone to know how to mine for scandium or to write Telegraph OpEds.
We only need enough people to have these skills to supply the desires of everyone for those outputs.
I can see the value of people being exposed to all of these opportunities as children but on the strict understanding that those who burst into tears at the very thought of programming (or scandium or the Telegraph) don't have to do it anymore.
I have entirely no clue at all about any of those things: although I do know that the readership of this site contains many who do and thus I can go off and think about Sc and bemoan having been fired by the Telegraph.
And as to Excel: no, really, how do you do anything at all in that?
Re: Unwarranted conclusion @Tim Worstal
I did in fact mention that you could short housing finance but not housing itself......
Re: Unwarranted conclusion
"I don't know if it's true across the pond, but here, if one does trade on information not generally available, it's called insider trading and is illegal"
Not quite true. You are absolutely allowed to trade on private information. For example, imagine that there was a publicly listed scandium mining company out there. There isn't, but just imagine there was. And then I knew that there was a new supplier coming to market. Me for example. In vast quantities, which will make the Sc price crumble. To below the price at which that listed company can make a profit.
Am I allowed to trade on that information? To short sell the stock of that listed Sc miner?
You bet I am. As much as I want to. I can trade on private information.
Now, change the situation a bit. Imagine you are the manager of that listed Sc company. And you find out about my new production process. You know your internal production costs and you know that my new production is going to bankrupt your company.
Are you allowed to trade on that private information? No, you're not. Because you have a fiduciary duty to your shareholders for the first reason and secondly, because you are using your own internal company information to trade in your own company's shares.
It's only certain sets of private information held by certain people that cannot be traded upon. Private information in general may be.
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