back to article Apple: You thought Google dodged taxes? Get a load of THIS

Apple has embarked on one of the biggest bond offerings in history as part of a ploy to avoid tax. Cupertino will soon begin issuing bonds in what will be one of the biggest debt sales of all time, it announced today. The plan is part of a scheme to funnel cash back to investors over the next three years. After its stock …

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  1. Rukario
    Mushroom

    Popcorn please...

    1. Anonymous Coward
      Devil

      Given that the US dollar is actually worthless

      And thanks the US Federal Reserve (private bank with official sounding name) and it's fractional lending scam, the USA has trillions in debts, loans and interest that can never ever be paid on money that never existed, and so when the cash house of cards soon implodes, Apple, and all their worthless shares, composed of worthless money, for their worthless shareholders, will all evaporate.

      So "Hooo Haaaa" for the Great American Delusion.

      And "OMG - Were Doomed - Eat the children" when it comes.

      1. JC_

        Re: Given that the US dollar is actually worthless

        "Given that the US dollar is actually worthless"

        If that's the case, then I'll happily give you £1 for every 10 of those worthless dollars you can find. If you prefer, I'll give you the equivalent of £1 in gold or bitcoin instead for those 10 dollars.

        If you're not happy to take that offer then you might be full of shit...

        1. Anonymous Coward
          Devil

          Re: Given that the US dollar is actually worthless

          Yeah OK... Gold for US dollars.

          Your on.

      2. Anonymous Coward
        Anonymous Coward

        Re: Given that the US dollar is actually worthless

        The Fed is a (private bank with official sounding name)?

        You've been reading those loony illuminati/birther/shape-changing lizard overlords websites again, haven't you?

    2. Shagbag
      Boffin

      "The market is going to be all over it,"

      ...said Todd Duvick, corporate credit analyst at Stifel Nicolaus. "It's a name that everyone follows and they're comfortable with. From a credit perspective it's going to be a good diversification name for a lot of accounts."

      Spoken like a true salesman. IIRC there were a lot of people saying the same thing about Facebook's IPO.

      We at El Reg know that Apple's new product pipeline is looking quite poor and this has been reflected in the 30%+ drop in its share price in the last 6 months (ie. the present value of growth opportunities has been heavily discounted by investors).

      1. JC_

        Re: "The market is going to be all over it,"

        "We at El Reg know that Apple's new product pipeline is looking quite poor "

        Who's this "we", fandroid?

        There's no risk in a bond issue for $16 billion when Apple already has nearly 10 times that in the bank and another 10 billion coming in every quarter.

        Hate Apple (and MS...) all you want - it's your right to be pathetic - but try to stay vaguely attached to reality.

        1. Andrew Baines Silver badge
          Stop

          Re: "The market is going to be all over it,"

          The debt is more than covered by their overseas assets, so no risk attached to the bonds as far as I can see.

          Problem is, what do they do next? At some point they'll have to spend the money they have overseas.

          1. Tom 13

            Re: so no risk attached to the bonds as far as I can see

            That's exactly what all those poor schlubs hawking and buying mortgage backed securities said before the bubble collapsed.

        2. reno79
          FAIL

          Re: "The market is going to be all over it,"

          He didn't mention anything about his preferred range on mobile manufacturer.

          I am an apple fan (and android, admittedly) myself but people like you are what gives us a bad name. Keep your vitriol to yourself please.

          Even I can see Apple need to do something different, if not drastic, to make up the kudos they've lost with underwhelming products for the last two product generations.

          1. JC_

            @reno79

            The market is going to be all over it. There's simply no question of Apple paying off the bonds - they have 145 billion in the bank and earned another 9.5 billion in the last quarter. Anyone who questions their future ability to pay 16 billion - even if they literally just burn the bond money - is simply fantasizing. Bonds aren't equivalent to shares, let alone shares in an IPO.

            As for my vitriol, Shagbag has earned it. Have a look at his posts - he's not only an Eadon-like fantasist, but also rather rude. If he can dish it out, he should be able to take it.

            Not send from an iPhone 'cause I prefer Android & WP.

            1. reno79

              Re: @reno79

              I'm not sure how your first paragraph there has anything to do with my post. I didn't question the capability of one of the worlds richest organisations to repay this sum. 6 months and they'll have covered it.

              What I mentioned was how Apple haven't really done anything radically different in their last two hardware revisions for their primary mobile devices (iPhone and iPad), and if we're allowed to forecast from their previous revisions of hardware for the next one, we won't see anything new in the 5S or next ipad, just a spec bump.

              As a company they are now just iterating, rather than innovating and this has started to reflect in their faltering stock price. They have an opportunity to invest a huge amount of cash into their product range to bring something new out but aside from a watch (which to many is doomed to failure before it's even out, but that is just opinion) there is little sign of this thinking changing with Cupertino.

              1. Tom 38 Silver badge

                Re: @reno79

                I don't understand this 'innovating' thing. There has been no innovation in phones for a very very long time. Processors get faster, interfaces get slightly slicker, but no phone has delivered anything innovative or special in a long time. Anything I said for phones also applies to tablets; tablets are just big phones.

                What I mentioned was how Apple haven't really done anything radically different in their last two hardware revisions for their primary mobile devices (iPhone and iPad), and if we're allowed to forecast from their previous revisions of hardware for the next one, we won't see anything new in the 5S or next ipad, just a spec bump.

                Shocker! Phones to remain phone like.

                1. Anonymous Coward
                  Anonymous Coward

                  Re: @reno79

                  Innovation?

                  But Apple was never involved in innovation - they had some nice design, yes, but Apple is really a marketing company.

                  The iPad? Not new - tablet PCs existed before - apple just made a bigger iPhone.

                  The IPhone? a PalmPilot crossed with a mobile phone.

                  The iPod? - less original than the iPhone really. Why do people think Apple created the MP3 player?

                  MacOS? - see Xerox parc

                  Apple 1 Computer? Well, it was assembled, unlike most other kits

                  1. All names Taken
                    Paris Hilton

                    Re: @reno79

                    It don't matter at all.

                    Life is but a dream - all is not what it seam.

                    But maybe the "innovation" theme with the big A is really and merely: we do what people want technology to do when they did not know it in the first place?

                    And then it inspired?

                  2. Frank Bough
                    FAIL

                    Re: @reno79

                    Boring and inaccurate, nice work.

                  3. Ru

                    Re: @reno79

                    But Apple was never involved in innovation - they had some nice design, yes, but Apple is really a marketing company.

                    By those standards, surely no-one has innovated in the computer field since the 80s.

                    I'd argue that good design is very much a valuable innovation in and of itself. I have never owned an Apple product and I don't anticpate doing so any time soon, but it would be remiss of me to suggest that they've not had a substantial (and largely positive) impact on the technology I generally use. The fact I don't particularly like their products or their policies is orthogonal.

                    The IPhone? a PalmPilot crossed with a mobile phone

                    I'd go further than that and suggest it was crossed with a second rate mobile phone. No 3G, after all. Nonetheless, it was a substantial step up from its Symbian and Windows Phone driven contemporaries, and has basically driven the design of every smartphone since then. I certainly don't want to go back to using devices with pre-iphone interfaces, do you?

                    The iPod? - less original than the iPhone really

                    I don't particularly care for the iPod, but it did drive the creation of the first serious online music store with (more or less) world wide reach, with the result that the big and compacent Big Media companies finally had to sit up and pay attention to modern technologies instead of trying to step on them. Bit of engineering, lot of marketing, but ultimately they created something that no-one else had managed, and everyone one else has benefitted, no?

    3. Ru
      Facepalm

      the bonds will be issued through Goldman Sachs

      Well, if you can't trust the giant vampire squid clamped to the face of humanity, who can you trust?

  2. Pypes

    increased dividends?

    My understanding was that apple paid no dividend, and as a result was sitting on mountains of cash.

    1. Anonymous Coward
      Anonymous Coward

      Re: increased dividends?

      They've been paying them for almost 2 years now.

    2. Trokair 1
      Trollface

      Re: increased dividends?

      Apple began a small dividend last year I believe. At the time I had assumed it would be a token dividend to help rationalize ownership of the stock to people who were strickly seeking dividend return. It currently sits at 1.85% yield which isn't great but isn't bad either in this market. Beats current US Inflation bonds by .09%

      1. David Kelly 2

        Re: increased dividends?

        $2.65 per share per quarter was the dividend announced last year. At $450/share that is 2.36%. Last week a $3.05 dividend was declared, 2.71% on $450.

  3. Anonymous Coward
    Anonymous Coward

    Didn't Lehman Brothers try lending more money than they could cover when they caused the crash of 2008?

    1. Ian Yates

      All banks "relend" investment, it's how they create the credit in the first place, which is what powers the economy.

      One view is that a "responsible" bank should hold enough assets at any time to cover a minimum of 20% of their exposure.

      And although Lehmans practiced some truly irresponsible trading and lending, they were far from the cause of GFC (sounds catchier).

  4. LinkOfHyrule
    Happy

    Obvious joke of the day...

    iDodgeTax

    Plus interesting fact - the spell checker in Firefox wants to correct the above to "Bridget"!?

  5. Anonymous Coward
    Anonymous Coward

    Only 35% in taxes ?

    That's less than I'm paying each year, and there are hefty fines if I miss the deadline for filing my tax return.

    1. Andrew Baines Silver badge
      FAIL

      Re: Only 35% in taxes ?

      They're a company, you're an individual. Get over it, or setup a dodgy charity scam and wait for the taxman to knock on your door.

      1. amanfromMars 1 Silver badge

        Companies are individuals too ..... albeit disguised in an artificial proxy

        They're a company, you're an individual. Get over it, or setup a dodgy charity scam and wait for the taxman to knock on your door. ...Andrew Baines Posted Wednesday 1st May 2013 08:33 GMT

        And quasi/pseudo religious misfits masquerading as faith foundations are another dodgy scam used to avoid taxation, Andrew Baines? ........ The Tony Blair Faith Foundation/P.O. Box 60519/London/W2 7JU/United Kingdom. The Tony Blair Faith Foundation is a charity registered in England, no1123243. The Tony Blair Faith Foundation is a company registered in England, no 06198959. Registered Office: 66 Lincoln Inn Fields/London/WC2A 3LH

    2. Bod

      Re: Only 35% in taxes ?

      "That's less than I'm paying each year, and there are hefty fines if I miss the deadline for filing my tax return."

      You want to get yourself a good accountant and arrange your affairs legally to not let the revenue "to put the largest possible shovel in your stores" (q. Lord Clyde).

    3. I Am Spartacus
      Mushroom

      Re: Only 35% in taxes ?

      Are we supposed to be sorry for you that you don't know the tax code well enough to avoid paying too much or should we just laugh?

    4. Tom 13

      Re: Only 35% in taxes ?

      Yes, but that's the 35% the government gets before you have to pay your more than 35% on it. Assuming of course you own iStock.

  6. Richard Boyce

    What will they do with the overseas assets?

    If those overseas assets are never to be imported into the U.S., it would seem that Apple will have to export its expenses to make use of them. How?

    Might it make good business sense to abandon the plans to build such a large and expensive "spaceship" in Cupertino and instead move people and R&D overseas?

    Of course, might it make much better sense for the U.S. taxpayer for the tax laws to be changed to stop such a large loss of taxes from the big companies? As business becomes more and more global, the world is becoming more and more of a tax haven.

    1. Tom 35 Silver badge

      Re: What will they do with the overseas assets?

      They just sit and hope for the republicans to get back in and have another tax holiday for their rich friends so Apple can bring in the cash tax free.

      I would not be surprised to learn that they have come up with a way to borrow in the US and payback overseas with tax free money.

    2. An0n C0w4rd

      Re: What will they do with the overseas assets?

      You forget that they buy a lot of stuff overseas already, not only assembly but also parts, etc.

      As for the R&D bit, I'd prefer they keep it in the west somewhere. I've seen what R&D out of Asia is like.

      As for the tax laws, they need serious overhaul, but the trick is getting the governments to act. No individual government wants to be the first to close the loopholes as they think they'll be at a disadvantage and companies will shift stuff around to minimise their tax exposure there and use the fact that other countries haven't caught up to their advantage. It requires co-ordinated action from multiple countries, and you've seen how well that has worked with such endeavours as emissions trading.

      In other words, don't hold your breath. I think there is a better chance of the Monster Raving Loonie Party becoming a serious contender in UK politics than there is of co-ordinated tax avoidance reduction across the EU, let alone the rest of the world.

      1. VeganVegan

        Re: What will they do with the overseas assets?

        They have a huge amount of cash overseas, accrued profit from their operations there (generated from working cash flow: pay for expenses, collect revenue from sales).

        Maybe they will use a big chunk of that cash to buy back their own stock, a move that was announced in parallel with the increased dividend payouts. One can envision Apple UK owning a piece of Apple USA, etc..

    3. Anonymous Coward
      Anonymous Coward

      Re: What will they do with the overseas assets?

      The really sad thing about this so called 'globalization' is that it pits poor nations against rich nations and workers in both countries are forced into a bidding war against each other which only enhances the income of multinationals.

    4. David Kelly 2

      Re: What will they do with the overseas assets?

      Thats exactly what Apple will have to do if the government will not let Apple import their earnings back to the USA. The earnings are kept where they were earned, and taxed, and Apple (as with any other smartly managed company) is kept and reinvested where ever the greatest value is to be found.

      Fools in government will borrow $785B to create a government-controlled "stimulus" but won't allow companies such as Apple to bring home foreign earnings without additional taxes. Apple could "stimulate" the US economy with $100B for no cost to the government or the taxpayer but for the fact the government is greedy and wants it for themselves.

      1. An0n C0w4rd

        Re: What will they do with the overseas assets?

        @David Kelly 2

        The assumption with any of these repatriation schemes is that the money is used to invest in the USA. Generally it isn't. 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.

        Or to put it another way: rich people find ways of getting richer, but the rest are left to fend for themselves.

        1. Badvok
          Mushroom

          Re: What will they do with the overseas assets?

          "Or to put it another way: rich people find ways of getting richer, but the rest are left to fend for themselves."

          God I hate that type of statement, isn't it truly amazing that some people really think that rich people simply stash all their money in a big safe to keep it away from all the grubby poor people?

          1. Anonymous Coward
            Anonymous Coward

            Re: What will they do with the overseas assets?

            "God I hate that type of statement, isn't it truly amazing that some people really think that rich people simply stash all their money in a big safe to keep it away from all the grubby poor people?"

            Don't they?

            I have no issue with people being rich. If money is your motivator, the got for it and earn your stake. BUT, conning the tax man by moving money about is a LOW LIFE activity (Schmit anyone). Others are paying your way which makes you a scum sucking money grabbing low life. You can't have it both ways.

            1. Oninoshiko
              Paris Hilton

              Re: What will they do with the overseas assets?

              BUT, conning the tax man by moving money about is a LOW LIFE activity (Schmit anyone).

              Isn't this about conning the taxman by NOT moving your money around?

          2. My Alter Ego

            Re: What will they do with the overseas assets?

            "God I hate that type of statement, isn't it truly amazing that some people really think that rich people simply stash all their money in a big safe to keep it away from all the grubby poor people?"

            Isn't that exactly what Apple are doing here?

        2. Anonymous Coward
          Anonymous Coward

          Re: What will they do with the overseas assets?

          So all those bond/stock holders and receivers of bonuses just stuffed the cash under their beds then? None of them went out and spent the cash on new cars, houses and stuff that might actually help the economy a bit more than giving it to the government to line their pockets with. The first thing people do when the bonus doesn't come through is sack the nanny/cleaner which might be a bit of a pain for them but is a damn sight worse for the person being fired (who is, by the way, no longer paying tax on that money). Still, so long as we can stick it to 'the rich' who cares?

          1. Anonymous Coward
            Anonymous Coward

            Re: What will they do with the overseas assets?

            "So all those bond/stock holders and receivers of bonuses just stuffed the cash under their beds then? None of them went out and spent the cash on new cars, houses and stuff that might actually help the economy a bit more than giving it to the government to line their pockets with. The first thing people do when the bonus doesn't come through is sack the nanny/cleaner which might be a bit of a pain for them but is a damn sight worse for the person being fired (who is, by the way, no longer paying tax on that money). Still, so long as we can stick it to 'the rich' who cares?"

            Missed the point! I thought the thread was tax avoidance, NOT bonus seekers. You need to stick to the point. No one has said contrary to what you have said.

          2. Anonymous Coward
            FAIL

            Re: What will they do with the overseas assets?

            Trickle down effect is nonsense, back when I did an econmics A Level they taught about the "Velocity of money".

            The basic premise is if you give 1 person £1 billion, they can only spend so much on cars, women, houses, yachts, etc.. say £600 million of it is returned into the economy.

            If you were to give a million people £1 million, most people would spend all of it so say £900 million is returned the to economy.

            While those numbers are plucked out of thin air the basic theory goes as you concentrate wealth within a system the rate at which money within the system moves around slows down. At a certain point the econmy will stall. The wealth gap is important for this reason if you want a healthy economy you want hundreds of millionaires rather than a few billionaires

        3. Tom 13

          @AC

          Keep reveling in your hatred of the rich and stay poor.

          Even if the money all went back to the shareholders, the shareholders are the ones who put the money at risk, and the execs are the ones who took the chance on the business plan. Eventually they spend the money on something, and that powers the economy. Even if they just stick it in CDs at the bank, that makes money available to other businesses through bank loans. The rich don't get that wy by sitting on their asses.

        4. Tim Worstal

          Re: What will they do with the overseas assets?

          "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.

          1. An0n C0w4rd
            Unhappy

            Re: What will they do with the overseas assets?

            @Tim

            Really? What on earth makes you think that the reinvestment will be limited to the US economy? People outside the US are allowed to own stocks and bonds in US listed companies, and even if the stock and bond holders *do* live in the USA, there is nothing to force them to invest in US based companies or buy goods made in the USA . How many of them go out and buy Audis or BMWs or Mercs? OK, the dealer in the USA gets a cut but the rest probably goes overseas. Or maybe they invest in an private jet made by Airbus, Embraer, etc.

            Also, I believe the last tax holiday was done because the companies themselves pledged to grow their US operations, hire more staff, etc. That might have happened with some of the money, but the vast majority of it went straight to the people who need it least, or they promptly outsourced everything to India or China and told their US workforce to get stuffed.

            Trickle down economics doesn't work as well as its supporters claim. All that happens when you cut taxes for the upper 1% of the income bracket is that they have even more money that doesn't go to the bottom of the income bracket, that probably need it more. If a person has a net worth measured in hundreds of millions (or more) already, an extra 5% off the top rate of tax for them isn't suddenly make them go out and hire more gardeners or have some redecorate the house and actually pass on their wealth.

            They're more likely to invest in companies and then demand said companies increase their profit margin by laying off their US staff and hiring overseas. Not exactly the stimulus you want, is it?

  7. Darryl

    Baling out an obscenely rich company by lending them money at crap interest rates?

    ...there's an app for that

  8. Natalie Gritpants
    WTF?

    So what happens when the bonds mature?

    Apple will need to find more cash to pay them back. Will they issue more bonds? This could keep going forever but there is interest to pay and that is eventually going to be greater than 35% tax.

    Maybe the bonds will be bought by overseas buyer and they can be repaid with offshore cash.

    1. Anonymous Coward
      Anonymous Coward

      Re: So what happens when the bonds mature?

      Just seen a comment on the FT.com story suggesting their offshore subsidiaries could buy the bonds with all their loose change. Then in a few years they could write the debt they owe themselves off. A bit like the Jimmy Carr scheme but not as funny.

    2. An0n C0w4rd

      Re: So what happens when the bonds mature?

      Depends on the distribution of debt across the different bonds. Note that some bonds mature in 10 and 30 years. I'm sure they can make enough money back in their USA business alone to pay off the bonds if they weight the distribution towards the longer maturation dates. They may also be some tax dodge relating to overseas bondholders, etc.

    3. Anonymous Coward
      Anonymous Coward

      Re: So what happens when the bonds mature?

      How bout Apple getting hold of some mafia style money laundering firm to broker the whole idea?

      1. Mephistro Silver badge
        Coat

        Re: So what happens when the bonds mature? (@ AC 19:24)

        "How bout Apple getting hold of some mafia style money laundering firm to broker the whole idea?"

        I think they are already working with Deloitte.

        1. amanfromMars 1 Silver badge

          Another Fiat Banking Fiasco in the Public Making for Private and Pirate Marketeering/Market Making

          "How bout Apple getting hold of some mafia style money laundering firm to broker the whole idea?"

          I think they are already working with Deloitte. …. Mephistro Posted Wednesday 1st May 2013 00:37 GMT

          The article mentions that two have already been briefed to perform their optimal sub-prime ponzi magic, Mephistro …….

          The bonds will be issued through Goldman Sachs as well as Deutsche Bank and demand is likely to be very high.

    4. Gannon (J.) Dick
      Thumb Up

      Re: So what happens when the bonds mature?

      Another iPonzi Scheme.

    5. Shagbag

      Re: So what happens when the bonds mature?

      Close to the maturity date, Apple will re-examine the tax situation. If it's still the same, they'll probably just 'roll', ie. issue new bonds to pay out the existing ones.

  9. Eddy Ito Silver badge

    iBonds

    The Apple product that sells out faster than any other iProduct in history.

  10. Anonymous Coward
    Anonymous Coward

    Worldwide taxes anyone

    US individuals are taxed on worldwide income, irrespective of jurisdiction. There is a $70K exemption if overseas, and that's all. Corporations are quick to claim citizen-like rights when it comes to bribing public officials (sorry, I meant campaign contributions).

    Why not extend the right to be taxed to worldwide earnings?

    Well, Apple would become a Cayman island corporation so fast their accountants might black out. Maybe an exit tax would be appropriate..say 50 percent of net worth! That would stop migration fast.

    1. jonathanb Silver badge

      Re: Worldwide taxes anyone

      Apple China makes stuff and sells it in China and to other Apple Group companies around the world. It isn't a US citizen as it is based in China. The American Apple might be.

  11. Nelbert Noggins

    This is nothing new, global company X finds ways to get money back to parent without being penalised.

    IBM and the holocaust is a real eye opener to the extents companies will go to to make a profit and get the money back to the parent company.

    1. gerryg
      Paris Hilton

      Godwin's law invoked

      <= just add a military band marching up her champs elysees

      1. Cpt Blue Bear
        FAIL

        Re: Godwin's law invoked

        Is there a corresponding law that predicts some muppet screaming "Godwin's Law"? If not I propose there should be.

        1. Sorry that handle is already taken. Silver badge

          Re: Godwin's law invoked

          Godwin's Law wasn't invoked here though.

          1. Oninoshiko
            WTF?

            Re: Godwin's law invoked

            Maybe you should read the title.

  12. DougS Silver badge

    Google and Microsoft have already done this

    Apple is far from the only US company employing this strategy. Google and Microsoft have both issued debt in recent years, despite having tens of billions of cash on their own balance sheets. Apple is just doing it bigger.

    FWIW, they won't be paying 35% to bring it back. They'll get a tax credit for taxes they've already paid overseas, though they can't take that credit until they bring the cash back. If you look carefully at their financials they've got many billions in future credits built up in taxes they've already paid on that overseas cash. The actual rate they pay is different for different 'piles', depending on where it was earned and what taxes have already been paid on it. I remember seeing some estimate a couple years back that they'd have to pay 23% on their overseas cash when it was brought back. That is likely a bit different now since the mix of countries where they earn the most has changed over the years.

  13. Anonymous Coward
    IT Angle

    re: Google and Microsoft have already done this

    "Google and Microsoft have both issued debt in recent years"

    Except when Microsoft does it, it doesn't get a whole article written about it ...

    "Microsoft Raises Nearly $3 Billion in Bond Sales"

    1. DougS Silver badge
      Coat

      Re: re: Google and Microsoft have already done this

      Apparently they did, or you wouldn't have something to link to :) I know, I know, you meant "at the Reg"...

    2. davefb
      WTF?

      Re: re: Google and Microsoft have already done this

      Didn't realise that m$ had $100billion offshore? Have they?

    3. xslogic
      Coat

      You mean...

      ...this is a rare case of Apple copying Microsoft, rather than vice-versa...

    4. Tom 38 Silver badge
      Headmaster

      Re: re: Google and Microsoft have already done this

      Except when Microsoft does it, it doesn't get a whole article written about it ...

      Ok, but then ...

      "Microsoft Raises Nearly $3 Billion in Bond Sales"

      you link to a whole article written about it.

  14. scarshapedstar
    Thumb Up

    Today I learned

    that swinge is a word.

  15. Joe Gurman

    Laughing all the way to the bank

    Wall Street shenanigans in general don't impress me, but I got a good laugh out of the phrase, "dismal lows of sub-$400 last week." I'm certain they were dismal for the poor people who bought high and were left holding the bag a few months ago when the hedge funds starting dumping Apple at over $600 a share. For those of us (I know, fanbois, helium inhalers, mouthbreathers, don't know real computer kit from a hole in the wall....) who bought Apple when it was $26 a share, and saw it split, $400 (oh, sorry, up a bit to $422 on this news) sounds _awfully_ good.

    Before you start cursing me for a plutocrat who lights his Cubans with tenners, please note that I own a total of 12 shares. ;-)

  16. ForthIsNotDead
    WTF?

    Eh?

    There's no such thing as a repatriation tax, so why would they have to pay another tax on profits they have already paid taxes on, just to wire it somewhere else?

    I can wire the profits from my business in Kazakhstan anywhere in the world for no penalties whatsoever, as long as the due taxes have been paid. Okay, I'll take a hit on the exchange rate, but that's it.

    1. Shagbag
      Thumb Up

      Re: Eh?

      Like most countries, the US does not tax the earnings of a foreign corporation until those earnings come back ('repatriated') to its US holding company via dividends. There are exceptions, eg. Controlled Foreign Corporations, whose earnings are deemed to have been repatriated, if you like, so that those foreign earnings are taxed in the US even though the cash never never goes anywhere near the US.

      Most large multinationals set up their corporate structures so that foreign 'subsidiaries' are not considered CFCs. This ensures no US tax is paid until the cash actually comes back into the US.

      It's usual for the US to allow a reduction in the US tax bill for the amount of foreign taxes paid (so that there's no double-payment of tax) but it's likely, in Apple's case, that little or not foreign tax has been paid because the foreign corporations are located in low-tax counties like Ireland (company tax rate = 12.5%).

      The upshot of all of this is that when the foreign earnings are repatriated (eg. so that the holding company can pay dividends or return capital to its shareholders) there is a large US tax liability that must be paid.

      No one likes paying tax (except Labour-voting lefties and, even then, they prefer someone else pays it, not them) and there are many US corporations with the same problem as Apple.

      It appears Apple's solution is to keep the cash offshore but raise new cash by issuing bonds to investors, and then use this new cash to pay shareholders. The bonds require regular interest payments, of course, but this can be met (in part) by the interest income on the deposits the foreign company has. Of course, there's some fiscal drag (since deposit rates are lower than borrowing rates) but maybe Apple has a plan for this, eg. invest in its own debt so that it's a cash merry-go-round - but with out the tax liability.

      Now that really would be a tax shag.

      1. Pie
        Thumb Up

        Re: Eh?

        It's comments like this that keeps me reading, thanks.

    2. Anonymous Coward
      Anonymous Coward

      Re: Eh?

      Dear ForthIsNotDead, the nature of US tax law is such that corporations in the US (as US citizens) pay taxes on domestic profits in the US as per normal. Their subsidiaries overseas pay taxes in their appropriate jurisdictions (i.e an Irish subsidiary pays tax in Ireland). This is where that double-Dutch sandwich thing that Amazon, Starbucks, Google etc are accused of, comes in.

      The IRS will require any profits repatriated to the US to be taxed at the appropriate tax rate in the US, however, if the profits have been taxed already at a lower rate (like in Ireland for example), the corporation must pay only the difference between the taxes due to be paid and the taxes already paid, provided the country where the profits are repatriated from has a double-taxation agreement with the US. So if 'corporation tax' is set at say 40% in the US, and the same (or equivalent) tax in Ireland is 15%, then the corporation is required to pay the difference, i.e. 25% of the repatriated profits.

      For any accountant it is a no-brainer to see the benefits of selling bonds at 4% interest to a consortium of banks instead of paying the US government 25% in taxes. The 4% interest is an expense in the end and reduces their tax liability. The 25% in taxes is not.

  17. Anonymous Coward
    Anonymous Coward

    These will of course be the first bonds ...

    ... with rounded corners.

  18. Green Nigel 42
    Megaphone

    SMB hell

    What are the solutions?

    1. Globalisation of tax

    2. A simple point of sale tax

    Both fraut with problems, inertia of self (politial)interest & potential loopholes. Would they be any less effective & inefficient?

    At present it is the SMB's who are trying to complete with higher margins of honestly paying their taxes that have to be suffering. Aren't these the true engines of the economies, is such actions by Apple again stifling growth,innovativation & the world economy for the benefit of Wall Street?

  19. Anonymous Coward
    Anonymous Coward

    What is so wrong with paying tax? Paying your way means your not a scum sucking lowlife living off other people.

    Sorry Apple, it is what it is!

    1. Green Nigel 42
      Megaphone

      Agree

      The tax they dodge has to be picked up by you, me & the honest with increased taxes, cuts & government dept.

      Such companies often hire at minimum wage which in effect is subsidised by benifits to make it a living one.

      So a portion of their profits & cash mountain is our tax, that has been sucked out of our economy.

    2. Tom 13

      Re: What is so wrong with paying tax?

      The taxes I owe for the services I use, nothing. The taxes I pay because self-righteous thugs like you have guilty consciences about the way they treat other people.. Everything.

      1. Sorry that handle is already taken. Silver badge

        Re: Tom13

        I have a mental image of you as a tax protester and/or hermit survivalist living in a hut at the top of a mountain in the remote wilderness.

        How you can afford an internet connection up there without participating in society has me stumped though.

  20. Green Nigel 42
    Megaphone

    Practical solutions

    It's nice to let off steam, offer opinions & hopefully test out ideas in an open forum here. The point is to take it further & do something!

    For myself I try not to patronise the tax cheats, by buying their stuff you purchase part of their guilt.

    Secondly, sign petitions, written, emailed as a group & talked to my MP, MEP, councillors.

    Yes, the little I do may be insignificant but as Gandhi said, it is important to do it.

    1. Anonymous Coward
      Anonymous Coward

      Re: Practical solutions

      "For myself I try not to patronise the tax cheats, by buying their stuff you purchase part of their guilt."

      I don’t!

      Not because I would be purchasing part of their guilt, but because I'm worth more and my integrity is not for sale!

      1. Green Nigel 42
        Thumb Up

        Re: Practical solutions

        Where as I agree with your preservation of personal integrity (hence my thumb up on your reply), you have done this by making a moral judgement that Apple has violated a moral standard and are guilty. If you had decided to purchase, knowing & accepting this, then you would have both endorsed & profited too from that original violation & therefore guilty by association.

    2. Tom 38 Silver badge

      Re: Practical solutions

      Apple, Google, Starbucks et al are doing nothing wrong, they are operating precisely under the rules they have been told to operate under.

      If you want to direct your ire at someone, it should be your MP, who has the ability to effect changes in tax laws, but chooses not to for reasons of political expedience.

      In other words, targeting a corporation is unlikely to have any effect. Since 1977, Nestle has been the target of a worldwide, co-ordinated activist boycott campaign. Nestle's profits last year, £6.5 billion pounds.

      If you want a corporation to change it's behaviour, legislate against it. If your legislators won't legislate against it, change your legislators.

      1. Green Nigel 42
        Thumb Up

        Re: Practical solutions

        I agree that Apple have not done anything illegal, but the point is they are morally deficient & actions are damaging to SMB's, hence to the economy & ultimately us.

        As I originally stated I have with others, approached, written, emailed (& received responses) my MP, the deputy PM on this & other issues.

        Unfortunately I agree that my & others decision not to patronise these companies will not be noticed, but I will do this out of principal & of course enable me to look my MP squarley in the eye!

    3. Green Nigel 42
      Happy

      Re: Practical solutions

      To those who thumbed down my exercising the democratic & market processes to attempt change.

      What actions do you propose?

      Please note that we have shamed the London Olympic sponsors into dropping plans to take the special tax dodges.

      We are now focusing our attention upon Npowers tax limiting practices. So democracy driven by the grass roots can work & will again.

  21. Green Nigel 42
    Megaphone

    Hypocrisy or ignorance

    Yesterday during one of those interminable wife's shopping trips, (usual does this make my bum look big in this trap! (no its your fat thst does it I think!) she decided to stop at a Starbucks for a break. I declined a coffee & justified being there to myself, by taking up a seat of a paying customer (sad cop out I know).

    Next to us where a group heatedly discussing corporate tax dodging as we are now. However they where supping their Latte's & enjoying the free Wifi surfing on their iPhones!

    You are what you buy?

  22. ravenviz

    2043?

    Well isn't time moving along?!

  23. Anonymous Coward
    Anonymous Coward

    Have a few shares?

    "The notes will be issued only in denominations of $2,000 and integral multiples of $1,000."

    Some rounding error.

  24. Zolko
    Pirate

    I don't understand

    What's the purpose of having 145 billion dollars if you can't use them ? What good is there having 145 billion ins a bank account if you have to borrow money whenever you need 17 billions ?

  25. bag o' spanners
    Devil

    What happens if Apple stock rediscovers its nosediving capabilities after another innovation-free year? Will St Steve convene a Ouija Board meeting to re-activate the company's hype glands?

    IIRC, investor confidence is one of those volatile commodities that can easily burst a bubble. If Samsung and their SE Asian cohorts continue to innovate relentlessly, with OLED and fancy shared memory chips, for instance, will that whittle away at current "certainties"? Comparing R&D budgets might offer a more accurate image of the future than the gloop provided by Wall Street hyenas.

  26. Mike Brown

    from the sounds of it

    they are skint*, and are needing to get real money out of the banks and into the company proper. Which is odd.

    *i dont mean "fags or food" skint btw, not normal people skint.

    1. Anonymous Coward
      Anonymous Coward

      Re: from the sounds of it

      Insightful financial analysis.

  27. redhunter

    Here we go again, another clueless article on U.S taxation. What Apple did is no different than if I decided to borrow money to use for a vacation instead of using the after tax proceeds of selling some appreciated investment I own. If I borrow the money, then I don't have to sell my investments and pay tax on the gain. Do I have some sort of duty to arrange my financial affairs in such a way as to make sure I pay the highest tax possible? If I don't then, why does Apple?

  28. Green Nigel 42
    Happy

    Their asset?

    Its the issuing of bonds against an asset that has been gained by questionable morals that has upset people here & which the article points to.

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