Re: ?
Sure. But only for expenses incurred outside the US.
They can't use it for an expense inside the US, no way Jose.
1389 publicly visible posts • joined 12 Feb 2008
"Consumption taxation".
You keep the Pigou taxes (APD, ciggies, booze, carbon emissions etc.....because they're there to correct market prices more than to raise cash). Then you abolish everything else.
Your tax system then comes down to taxing people on their spending. But you run it like an income tax.
Here's your income for this year. Now, how much of that did you save? That's all tax free. So you pay "income tax" on your spending.
Any earnings from your savings are also tax free: as long as you reinvest them. However, if you spend the earnings from your savings, or draw down your savings to spend the capital, then you pay that "income tax" on the amount that you have taken out of your savings.
Thus earnings from labour or earnings from capital are taxed at the same rate: nothing if you invest them or the full whack if you spend them. It's a consumption tax.
The Economist spent most of the 80s touting this as an idea but no one wanted to listen.
True. But at some point those loans need to be repaid. Either out of US made profits, which will pay the US corporate income tax, or out of those foreign made profits, which will have to be brought into the US and will thus pay the US corporate income tax.
The one thing that Apple simply cannot do is borrow the money abroad, pay it out as dividends, and then use the profits stacked up offshore to repay the loans.
Absent a tax amnesty Apple simply cannot get those foreign profits into the hands of the shareholders without paying corporate income tax on said profits.
You can delay for a long long time but true avoidance is much more difficult.
The bit of Bath I grew up in got bombed in the Baedecker raids. One plane dropped a stick right across the avenue the parentals house is in. Looking at it now you can see a new house on one side of the avenue, 80 years newer than those on either side: and exactly the same on the opposite side.
That's how the bombs fell.
About 3 years back the parents changed one of the bedrooms overlooking that middle of the avenue into a bathroom. On doing the alterations they found that the window boxes (ie, what the sashes fit into, not the plant pots outside) were still pushed in a few inches from the bomb blast of those WWII explosions.
"In order to sell your product here, your company must have a branch office here that is registered with companies house, and declares its accounts just like every other company."
That's what the current law is!
Your "branch office" is defined under the "permanent establishment" rules. If you've got one of those your profits in hte country are subject to the local profit tax. If you don't then you don't.
And obviously, it's got to be possible for people to make some sales in country without actually having a permanent establishment in the country. Some e-bay seller shipping you an antique Hornby for you collection from Germany (or whatever). We're not going to say that he's got to have a UK company now, are we?
At the other end the company owning the land upon which a shopping centre is built pretty obviuously does have a permanent establishment in the UK.
All of the arguments that are going on are about this definition of what is and is not a permanent establishment. For example, international law has said for well over half a century that using a warehouse to aid in selling isn't a permananet establishment. So, Amazon's not actually in the UK then.
Saying that you must have a branch off that is registered is just fine. But now define branch office: that's exactly what the problem is.
"The IRS's requirement to withhold tax from a salary/payment requires a social security number."
Amusingly, for writers at least, this is the other way around. Providing an SSN means that the employer of a freelance writer will not with hold tax from your payments.
Permanent nomad status.
But they'll only let you do this for a few years. They will eventually insist that you've got to decalre residency somewhere. Bahamas is a good idea: no income, profit, inheritance taxes. Horrendous, vast, VAT and import duties though. So be resident there but perhaps not live there very much......There's a weird bit of Italy surrounded by Switzerland that has an interesting system too.....
Starbucks is actually an amusing case. For when the accounts were pulled apart, it turns out that they really weren't making a profit in the UK. Add back in the royalty for the name paid to Holland, the premium on coffee beans to Switzerland etc and they still weren't making a profit.
The FT's alphaville did it once and Vince Cable had his department look at it as well: same answer both times.
Where was all the money going? Well, anyone who had read Ricardo on rent (or even Tim Halford's excellent description of it in "Undercover Economist", using the example of coffee shops)would say that it's all gone to the landlords. Who do, of course, pay tax on their rents 'coz there's no way you can hide a piece of land.
The reason that they could be saying something different to the shareholders is simply that tax accounting and shareholder accounting are not the same thing.
Last I saw (and this isn't a story I particularly follow) they were working to get their Ti aerospace accredited. That's where all the money in Ti is, in making plane parts. And, given the way in which a metal failure in a plane at altitude produces a fiery burning death in a deep hole for hundreds of people, that accreditation takes time to get.
One industry contact worked with them on neodymium (the process should theoretically work on a number of metals) and was deeply unimpressed at the quality of produiction. Pity really, because we need a lot of Nd for all those windmills.
The most interesting part of the story to me is that when they did decide to commercialise they set up in Sheffield (or Rotherham? Some hellish Northern city anyway). Not quite where you'd expect for glamourous new tech. Except, that's where all the people who know how to make weird metals are, where all the support services are. Economic geography does produce clusters like that. If you're going to do weird metals then that area. Chlorine chemistry then Tyneside. Fluorine chemistry, Mersey area. Pottery, then Stoke (and indeed the most recent UK new pottery was in Stoke).
Path dependence to be posh about it........
Erm: The Cambridge process for Ti. The FFC process? Being used by Metalysis right now.
The only problem with it being that it's not quite as wondrous as was at first thought.
And yes, El Reg's metals spiv (that's me folks!) does indeed know about this. Back when they first designed the system I advised on what markets for which metals they might want to look at (or more accurately, which ones they should forget about).
Err, that's actually what US tax law is right now. With one slight proviso. You only pay that difference between US tax rates and foreign tax rates if you take the profits back into the US.
The UK tax system worked pretty much this way until recently too. The Controlled Foreign Corporation rules. You, a UK company, stacked up your foreign profits in some tax haven. HMRC said "Yup, we see what you're fdoing. Please pay us the difference between UK tax rates and what you've already paid".
The only problem with this was that the EU decided it was illegal (this was the finding of the Cadbury and Vodafone cases).
Err:
"Wow. Clearly the author does not believe that there might be tangible benefits to be had from a system of moving people from the non-capital area into said area in doublequick time above and beyond those of the weekday business world. I wonder what the London restaurant, theatre, museum and art gallery owners think about that?"
The entire piece is about how you calculate whether there are benefits or not. Net benefits that is. To accuse me of not believing that there might be benefits when I'm explaining the system by which we try to decide whether there are benefits is a bit much really....
"Given you will hardly have any major road issues,"
The A 22, the motorway east west along the Algarve, was recently upgraded to a toll road. The EU insisted: roads built with EU money should be toll roads.
Current accounting suggests that the costs of collecting the tolls are higher than the revenue from the tolls.....
Different problems here, to be sure, but we do have them.
Sure.
I do get that.
My comment is rather that someone seeking risk capital is usually offering some piece of the action in return for it.
Do note also that risk capital doesn't have to be returned: the adventure goes bust then it's the adventure that does, not the entrepreneur.
I can imagine someone providing that 50k in return for (obviously, assuming the numbers stack up of course) some share in the adventure. In fact, I've got someone in mind who would probably do so. In fact, having had a very brief chat about it with him, really would probably do so.
On reasonable terms too. But this sort of thing: if you can finance it with loans and are willing to take on that personal responsibility for paying the loans back, well, good luck to you and all who sail in the adventure.
But if you want capital, not debt, then a slice of the action will have to be sold. The point at the end being that if a slice of the adventure is to be sold then that capital is there and available, assuming, as above, that the numbers do stack up.
"The corporation is now viewed, at least under US law, as a natural person (flesh and blood)"
No, it ain't. The corporation is a legal person, just as it always has been. A natural person is, by definition, an 'uman being, not a legal person.
The question was rather different. It was "Do legal persons have the same First Amendment rights as natural persons?" and the answer came back "Pretty much, yes."
"You sound deluded my friend, you really think Google, Facebook, et al really contribute that greatly to the domestic economy?"
Err, yes, yes I do.
The contribution of a company (or any organisation) is measured by the production of that company that we get to consume. The value of Google to us is that we get Google to use. Yes, I understand that that argument fails somewhat when discussing Facebook: but 1 billion people do like it.
Try this one. We're going to measure the contribution to hte domestic economy by looking at how much tax people pay, yes? You hint at that above.
Excellent: so, the NHS pays not corporate taxation at all, Google pays at least some. Google is therefore more valuable to the UK economy than the NHS, yes?
No, obviously it isn't, the conclusion is nonsensical. Therefore the original contention must be: that tax contribution determines the value to hte domestic economy.
The value of the NHS is reasonable even if not perfect health care for 65 million people. The value of Google is being able to use Google. Nowt about taxes paid in either case.
QED.
Your metals wide boy here.
Titanium oxide (TiO2) is indeed the white pigment in white paint. $500 a tonne or summat at the gates of the manufacturing plant. Easy to make (stick ilmenite into a furnace with coal, light coal, feed in chlorine, separate the bits through distillation of the various chlorides, all gases at these temperatures).
Ti metal is a great deal more expensive. Last I looked $15 a kg but could be very different from that now. The process of TiO2 to Ti is hugely energy intensive.
"The last tax holiday for reparation back to the USA most of the funds went to stockholders and bondholders and bonuses to executives and things like that and did sweet F.A. to boost the economy."
And the money going to stockholders and bondholders and executives will do what: either be spent in hte US economy or be invested again, anew, in the US economy. Which is the very definition of stimulus in fact.
With some investors in this company (not because I'm involved, just because I've been chatting to them).
And none of us can work out where the tax bill would come from. Wouldn't be UK tax, under SSE.
And we sorta assume that the Verizon stake is held through Cayman or somewhere, meaning no US tax. So where is the bill to come from?
"Hodge stood by that stance today.
"All we are saying is that multinational companies should pay an appropriate amount of tax relative to the profits they make from their economic activity in this country," she insisted."
Given that you're in Parliament why don't you try and do something about the law then?
Or would it mean that you'd have to recognise that it's EU law that allows Google to do what it does? Indeed, encourages it?
I was on Sky News with her once and pointed this out to her. It's all EU law. She just said "well, I don't agree",
Because it gives us time to deal with the problem rather than having to cram all of our abatement into the next decade as some loons keep telling us we must do.
Two things.
1) Who thinks that in 50 years time solar cells, fuel cells, thorium reactors etc, are going to be anything like as expensive as they are now? Quite, so, if we've a few decades to change our ways this is good for us. We get to install these things when they become cheaper. And we've got all sorts of people telling us that solar is going to be cheaper than coal any day now (I think perhaps a decade but that's just an opinion). so, we can all install it when it is cheaper and then the problem's over, isn't it?
2) It enables us to work with the capital cycle. Ripping down power plants we've already built makes us poorer. When they run out, as they of course will, we'll have to replace them with something or other. If we've a few decades to deal with all of this then we can, instead of junking a lot of what we've got (making us poorer) simply insist that the new stuff we build in the future is low/non-carbon whatever.
This is essentially the William Nordhaus view of the whole subject and he's pretty much the economist who has been calling it right for the past 20 years.
Grrr.
"There's currently only about 40 years of proven reserves left"
A useful definition of proven reserves is the stuff that we've prepared to use in the next few decades. That we're going to use in the next few decades what we're prepared for our use in the next few decades isn't really all that exciting a notion.
This also explains why reserves have been 40 years worth for a century. Because every year some people take some of the *resources* and convert the into *reserves* by preparing them for our use.
Please note that the conversion of resources into reserves does not require finding new lakes of the stuff. Finding new lakes is an increase in resources.
We are accepting that bubbles are capital misallocation. And that capitalists lose by such. We're also noting a silver lining: which is that sometimes, consumers benefit from such misallocation.
There's an awful lot resting on that "sometimes" tho.
BTW, I do jokingly refer to myself as a capitalist. And certianly, the day job involves me acting like one. However, in the political sphere, in the "what should we all be doing" thing, I argue that markets are much, much, more important than capitalism.
It wouldn't worry me particularly if we became socialist: companies are mutuals, worker or customer co ops like John Lewis, the Co Op itself for example. I'd argue that it's not optimal to try and run something like an oil company in that manner but it wouldn't really worry me.
If someone decided to abolish markets as the distribution mechanism and the great calculating engine then that would horrify me, have me on the barricades.
Dang.
"Judging by the number of Bitcoin articles I've seen in the past few weeks it seems like the 'currency' is worth more to journalists than anyone else."
Did you have to tell everyone that?
TBF tho, much the same is true of any subject that people write about a lot. I'd wager that Maggie's death has made more money for journos than whatever estate she might have left for example.
Indeed, there's an "optimal" length there.
Too long and the cervix, not really known as an erogenous zone, risks getting bruised (as goes the glans actually). Thus "too" long means not fully entering the vagina.
On the other hand, fully entering brings the mons pubis into contact, or at least aids in stimulation of, the clitoris (in most of the face to face variations at least).
Girth is another matter but length, definitely a trade off taking place there.
There's a time value to money. Perhaps there shouldn't be but there is. Humans just behave as if £1 today is worth more than £1 in 365 days time.
Thus interest.
I'm afraid that really is it.
As to banks, the real thing they do is maturity transformation. They take in short term savings (their deposits) and transform them into long term loans. Very few people want to save cash for 30 years but there's an awful lot of people who would like to borrow it for that time. Thus, someone, somewhere, must collect the shrt term deposits and make them into long term loans.
And that's banking. If you borrow short and lend long you're a bank. If you don't, you're not.
This doesn't mean that banks or interest have to be the way they are right now: but something or other that performs the same function as both of them will indeed exist.
Re the RHT.
http://www.iea.org.uk/publications/research/the-case-against-a-financial-transactions-tax-web-publication
That also formed the basis of my evidence to the Lords Committee on the tax.
Essemtially, it'll shrink the economy so much that total tax revenues will fall. Plus, it will reduce liqudity so much that prices will become *more* volatile, not less.
There's also a much more general point. Transactions taxes are simply a bad idea. Taxes on incomes, final consumption and the like might not be all that good: but transactions taxes are definitely worse.
Strange that German had to spend even more than the UK to rescue its banking system then really.
And yes, they really did.
And, err, the Sparkasse system is pretty much the Spanish caja one that has just imploded entirely.
I might be willing to agree that the German system is a good one when run by Germans but perhaps not if run by Spaniards. But that's a comment about the cutlure, not the structure of the banks.
Now that is amusing.
"was in the RAF from the thirties (and knew and admired Aircraftman Shaw, i.e T.E Lawrence)"
My grandfather, about the same age, was also RAF and at one point in the 30s was TE Shaw's commanding officer.
That two RAF men who knew Shaw have grandchildren running around is not particularly unlikely. But that one would comment on a piece written by the other is rather more so.
The argument about why companies are charging more in Oz.
Companies do not tot up their costs and then decide what the price is going to be. They try, instead, to work out what is the absolute maximum they can shake out of the customer. Then they charge that.
The reason that companies charge more in Oz? Because they think they can.
And that's it, there is no other reason at all.
Out here in exile the Telegraph has been "paywalled" for some months now.
Not that it makes any damn difference. Clear cookies and you're away.
True story: I used to write for their blogs. Used to get paid (beer money) to do so. They decided to spend their money in other ways: fair enough, it's their money. They then invited me to continue to write for free. Also fair enough.
When I asked, being in foreign, if I could have a free £1.99 sub in return for writing for free I was told no, I couldn't. Wouldn't it be a good idea if I wrote for them for free but had to pay to read the paper instead?
Err, no, no it wouldn't.