Shame they pay no tax elsewhere
US megacorp maggots
Apple announced today it will start to repatriate back to America some of the massive profits it accumulated outside the USA – and will use the cash to Make America Great Again. We’re using the Trump catchphrase because Apple’s action is only possible thanks to the new tax arrangements that the US president campaigned on, …
I do agree with the sentiment, and I also get very angry when these hugely profitable monsters come cap in hand to taxpayers wanting more and more help because they create jobs (allegedly).
It does seem odd that Uncle Sam want them to pay tax when they've already paid tax somewhere else, even if it's not much.
As far as I'm aware there are such things as tax credits.
America has always double-taxed things. They basically don't care what the outside world taxed you, they will tax you too.
Many dual-citizenship people find this out - pay US taxes while living abroad, or give up the US status. It's a very common dilemma. Even if you use certain credits to not have to pay the US tax, you still have to fill out all the US tax forms to claim that even if you haven't lived there for decades. I don't know of another country that does that.
And UK banks (amongst many others) are obliged to assist the US treasury in enforcing their taxation rules.
If you're a US citizen, and you live in the UK (for example), you probably won't have to pay US taxes because you're already paying higher UK taxes, but you will have to prove to the US tax authorities that you are indeed paying those UK taxes. Of course, the US has a tax system from the last century so you'll have to fill out all those forms yourself (or pay someone else to do it for you, which is the intention of keeping it so manual).
As others have pointed out, no other country will try and tax you on income you made elsewhere, one of my friends has never taken up his duel US citizenship because of this.
They pay taxes as, when and where required. If tax situations allow the Double Dutch Irish Sandwich to exist, then that's a problem for the Netherlands and Ireland to resolve. The Dutch know this, they are not happy about it (well, the citizens aren't by the tone of the conversations I had in Amsterdam last night), and thus it continues to be a problem. Ireland also knows they have to resolve this (and they have).
The American model allowed 'deferred taxes' to exist, so the cash pile just grew and grew and grew. If they ('deferred taxes') couldn't exist, the $250 billion cash pile wouldn't exist either.
I think you missed the part stating that they had already paid the tax in the jurisdiction where they had the money. It is not double taxed. The issue is that the US corporate tax is much higher, one of the highest anywhere. They get a credit for what they pay elsewhere, but they still owe the difference. While they technically owed the difference anyway, they could have what they owe deferred (indefinitely) until they actually brought it back (repatriated it). Since it was over a 35% tax rate, they left it offshore and deferred for many years. The new tax code allows them a one-time tax break to repatriate the cash for cheap, relatively speaking.
So is it a tax break for Apple? Technically, yes, but in practice the US government is getting $38 billion instead of zero. Seems like a good deal to me. 15% of hundreds of billions is much more tax than 35% of nothing.
Just goes to show that the debate about "muh tax leeches" is a completely wrong one: US government always spend more than there are.
That's 3.8% of Obama-Hillary useless "nuke from planes" program btw (first estimation). Trump's "small nukes to bust a city or two" program has not seen its cost estimated yet.
Then, the Trump-friendly tax reform bill passed late last year offering a one-off discount rate of 15.5 per cent for repatriated profits.
Compare to their single digital corporate tax by leaving the profit outside, it doesn't feel like Apple will bring 'all' of their profit back to USA.
If you think like a multi-international Apple guy (Tim Cook?), bring 'all' profit back doesn't give much benefit unless you really need USA stuff. The factories and everything are outside, so the profit outside can be used to continue manufacturing iPhone without getting taxed by the USA, which saves 15.5 percent in cost. So unless Apple guy want more USA designers, USA Apple campuses, USA Apple servers, or USA Apple buildings, there are little reasons they would bring all the profit back. Even when you look at it in another direction, if Apple sold an iPhone in Singapore, it's profit in Singapore that is taxed in Singapore and can be reinvested in Singapore. Why would you bring it back and get taxed 15.5 percent?
According to Donald 'lets tweet' Trump, he's going to make america great again (MAGA). He said that he's going to 'fix' the infrastructure (roads etc). ROFL
A report a few years ago said that of every 100$ dished out by DC for infrastructure $48 was spent on Lawyers, 30$ spent in the state governments leaving a miserly $32 to be spent on the ground.
That Apple tax take won't go very far if that new metro tunnel in NYC is anything to go by as it costs $3.1B/mile.
The sums are mindboggling. Carillion was a minnow at this game when compared to the Yanks.
Why would you bring it back and get taxed 15.5 percent?
Because it is running out of options to be taxed less. There is only a handful of non-tax heaven countries with rates under 15. In the Eu it is just Bulgaria and Hungary.
Combined PR + political move too. Tim Cook is a very political animal. He has just bought the service of Uncle Sam's diplomatic attack dogs without actually paying more than he should have paid to start off with in Ireland. While before, US authorities were helping other countries trace what Apple is doing (Eu investigation started as a result of reading the notes from questioning Tim by Congress). Now, not so much.
"There is only a handful of non-tax heaven countries with rates under 15. In the Eu it is just Bulgaria and Hungary."
Just wait until the UK is out of the EU. If the local business tax take sinks low enough becoming a tax haven will be a viable proposition.
"Just wait until the UK is out of the EU. If the local business tax take sinks low enough becoming a tax haven will be a viable proposition"
Whilst I do think UK can do quite well for itself outside of EU control, I don't think we want to be starting a trade war.
"So unless Apple guy want more USA designers, USA Apple campuses, USA Apple servers, or USA Apple buildings, there are little reasons they would bring all the profit back."
Surely all these things you list are expenses which would be set against tax. Paying out money in this way reduces profits on which the tax is due. The reason to bring back profits is to pay dividends. In the past Apple has borrowed money to pay dividends. Now they can repay those loans. They'll have time-shifted the tax liabilities on the profits distributed as dividends from the past, when the tax would have been higher, to the present.
It's a US company with (mostly) US shareholders. They make things people like to buy and sell them all over the world at a profit. They pay local sales and other taxes (VAT, business rates on their shops, salaries, tax and NI on local employees, and so on), but the profit goes back to their owners and is taxed where the company is registered. What's the story here?
The only anomaly is that for years US corporation tax rates were widely regarded as uncompetitively high (nearly twice the rate in the UK, for example) and they've been talking about reforming the system for decades. Apple, in common with most other US corporations with signficant overseas earnings, temporarily kept their overseas revenues in a holding bin waiting for the date of the much promised reform so they could finally repatriate the earnings where they belong. That day has now come.
"The recipients and their families when they use the income to buy stuff."
They use their net income to buy stuff - net after the tax has been deducted by the employer (in this case Apple) and passed on to the tax office. That was the point I was making - tax on income is a tax paid by the employee, not the employer.
The person I was replying to seemed to suggest it was a tax paid by Apple. It isn't - they're just collecting it from the employee and handing it over.
Wait, what? Who pays VAT? Who pays tax on wages and salaries?
Are you being deliberately obtuse? There is a 20% tax on turnover on EVERYTHING Apple sells in the UK. It's called VAT. And they have Apple Stores and other back off office staff, so they employ lots of staff in the UK, all subject to national insurance and so on. So Apple's UK operations pay UK tax. And the profit goes back to where the parent company is registered subject to US corporation tax.
"There is a 20% tax on turnover on EVERYTHING Apple sells in the UK. It's called VAT."
VAT is not a "20% tax on turnover".
It is a tax added to the price of the goods or services and is ultimately paid by the consumer. The company is merely collecting it from the end customer, and hands it over minus any VAT they themselves have paid on allowable goods or services they have purchased along the way.
"so they employ lots of staff in the UK, all subject to national insurance and so on."
They pay employers' national insurance contributions, yes - but that isn't a tax on the company, as such. However: "and so on"? You originally claimed they paid "tax and NI on local employees." The tax is deducted FROM the employees wages and salaries (along with the employees' own NI contributions). Apple isn't paying anything here (other than the ers' contribution as I said) - just like with the VAT, they are merely collecting it, this time from the employees, and then handing it over to the tax man.
"faster - maybe, for the first month or two, but degrades over time and, ime, ends up unresponsive"
That's more of an Apple problem. Big performance changes usually only happen with major OS updates, and as we all know, Android phone manufacturers don't tend to bother with that. Apple enforces these upgrades quite fiercely, so iThings tend to become unusably slow after a few years.
"Cheaper - worryingly so in some cases"
Worrying for whom? If you can't afford £1,000 for a top-of-the-line iPhone or £700ish for a top of the line Android (or you have more sense than money) then why not buy cheaper? If you don't need or want the latest 'features', again why not buy cheaper? Not everyone is dumb enough to buy into the annual "upgrade" mania.
"faster - maybe, for the first month or two, but degrades over time and, ime, ends up unresponsive"
Hahaha...really? I've either kept or passed on all of my Android phones for years and whilst none of us are into playing games etc on them, they've remained pretty much as fast as when bought with a little care and attention - even after the (admittedly few, in most cases) OS upgrades are applied. Apple...slowed down some of their older phones in the background because of battery wear. Or openly admit that newer OS versions will be feature limited and/or slow on older kit. So really horses, for courses, eh?
"fuck rounded corners - oh, I see, still upset by Apple vs Samsung......"
hmmm...'kay. You're holding it wrong.
That said I just looked around the office and funnily enough every handset in view has rounded corners...go figure. Who knew that lawyers are not like most other people?
I suspect the view from up on your soap box is a little low on the details. Perhaps climb down and take a look around occasionally?
When the tax reform went through I already knew it would generate growth and get companies to invest in the US economy (although I don't really get why Apple is being applauded for finally becoming less immoral, but that's another discussion I guess), my gripe is mostly about those cuts going to the wrong people. the tax bonus seems like a lot of money, but on the total scale it's peanuts and the money Apple gets in is going to make the rich richer, Joe Average isn't going to see any of it.
Less immoral? This is profit that should have had taxes paid in countries all over the world, the money was made in those countries and the fair, i.e. headline, tax rate in those countries should have been paid. The fact that the US taxes incoming no matter where it is made, even outside the US, is an anomaly.
International agreements on corporate taxation are (a) profits are taxed, not revenues (there's a good reason for this, if you think about it); and (b) they are due where the profits are made. It's difficult to argue other than the vast bulk of Apple's profits are generated in Cupertino. The US anomaly is that taxes are paid only when the monies are repatriated; and having an unusually high (by international standards) rate of corporate tax. Trump has fixed the latter issue, with the predictable results we now see.
"Trump has fixed the latter issue, with the predictable results we now see."
Has he, though?
Part of the reason for the offshore cash piles that many US companies have built up is that the Bush administration gave a tax holiday on repatriating profits. Companies basically took this as a signal that, if they just held enough money offshore, Republican administrations would give cut-rate prices to bring the money home sooner or later. Trump's just confirmed that.
Odds are, most multinationals will look at the 20% 'normal' rate, look at the 15.5% 'one-off' rate, and decide that they can expect the same or better 'one off' deal in about ten years, so why pay more? The money is more useful for investment outside the US anyway, and shareholders can happily wait a decade for a windfall payout. And Republicans will use that to argue for slashing the rate to 10% next time - with a 5% one-off rate for the backlog.
The hiring in the US they promise over the next five years is actually slightly less than the hiring they've done in the US over the past five years, so no additional benefit from the tax cut. The capital expenditures they are promising in the next five years is 1/3 of their projected capital spending (using the last couple years as a baseline) and Apple makes 36% of their revenue in the US so that's pretty much exactly what you'd expect and again nothing extra from the tax cut.
The main reason they're doing this is to counter the inevitable backlash they'll get when they announce what they plan to do with the bulk of the $200 billion after tax amount they're bringing home. They're going to increase buybacks and dividend growth, i.e. return it to shareholders. It isn't going to result in any more jobs created or investment made in the US than if the tax law hadn't passed and they had to keep that money overseas.
Still that $38 billion, and the tens of billions from other companies bringing money home, will create a one time drop in the deficit for 2018 which I'm sure Trump will take credit for. And then when it inevitably goes back up again in 2019 because that one time shot in the arm is over, he'll blame the democrats, or Mueller investigation, or whatever.
American companies with offshore operations previously faced the odd situation of having to pay tax in jurisdictions they make their money, then pay US taxes at 35 per cent on those profits too. Rather than pay twice, plenty left their cash offshore.
Are you sure about that? IANAtaxL, but I understood that, just as for US individuals, foreign taxes paid can be offset against US taxes due. Hence the EU tax grab is actually a raid on the US Treasury, not Apple's or Google's.
What happens if the EU repeats their retrospective tax grabs will be an interesting one for the lawyers.
Yeah, but if you've only paid tax locally at 15%, presumably you must pay at least the *difference* between that and 35% when repatriating.
Better to leave it offshore, and bet on there being a tax amnesty every few years. Meanwhile you can invest your cash pile in higher-growth economies.
"Meanwhile you can invest your cash pile in higher-growth economies."
I wonder what the knock effects will be in the places where Apple et al have stashed their cash? It's not as if it's sitting, unloved and unused in vaults around the world. It's invested and "working" for it;s owners. In smaller economies, a sudden withdrawal of $billions could be noticeable in the economy.
Manufacturing jobs are a Trump fetish, and the repatriation discount a pet policy, so it’s no surprise the tweeter-in-chief emitted the following today:
This is just bringing some cash back to the USA; the factories will remain in Asia. I suspect he'll forget to mention this :)
In 8 years under Barry Obama the US had:
- No GDP rise above 3% in any year (Barry was the first US President in history to achieve this feat)
- Record number of people on food stamps
- Increased the nation debt by $7 TRILLION dollars
- Covert drone wars (over 20k bombs dropped in 2016)
- Growth of ISIS which Barry said it would "take many years to defeat"
- One of the highest personal and corporate tax rates in the world
- Record increases in the cost of medical insurance
- Record numbers of illegal immigration
- Record gun crime in inner cities
During that time Barry increased his personal wealth from around $1m to $40m all on a 'messily' $470k a year salary.
In a single year Trump has:
- Record numbers in employment
- Record numbers of minorities in employment
- Record highs on the stock market
- Record tax cuts
- ISIS defeated
- GDP growth up to 3.3%
All the while donating his salary to good causes and has decreased his personal wealth by around £1billion.
Now companies across america are repatriating jobs and wealth and somehow this is a bad thing?
Is it any wonder trust in the media is at an all time low as they continue to slant every Trump and Brexit news story to suit their only political agendas?
To be fair, Trump deliberately causes much of his publicity. Remember that he is an anti establishment figure in charge of the establishment. This is usually instant death for the anti establishment figure as they become the establishment.
Trump however is (IMO) keeping his support base onside by deliberately doing things to cause his political opponents to scream blue murder, which makes his supporters think that he's hurting the metropolitan rich as much as they have hurt people on low wages in manufacturing and service jobs over the last decade or so.
He can also manage damaging media stories by taking advantage of the media having the attention span of a goldfish and doing things that attract news stories and followups for weeks.
He is definately a lot more intelligent than a lot of people give him credit for, and i'm far from convinced that he's going to be out of office at the next election because people underestimate him so much. In fact, i'd hazard a guess that this is going to look very similar to his next election strategy pitched at everywhere other than cities:-
The media says how horrible I am, but you personally are better off. Your wages are higher because:-
A) i've kicked out as many illegal immigrants as I can and reformed immigration laws reducing competition for your jobs, so your wages have risen.
B) i've reduced taxes, thus increasing your employers income so they can afford to pay you more.
C) i've reduced taxes so that you keep more of your hard earned money.
D) The media lied to you about all of the above, look at your pay packet! If I get in them I will extend these tax breaks and you will continue to be better off. If my enemies get in, they are going to axe all of my work and you will be massively worse off. Vote Trump to make america great for hard working workers!
Personally, I think that stands a reasonable chance of winning, because the media is only really persuading the people who already hate trump that he can be safely underestimated.
And killing US citizens without judicial oversight.
And expansion of the surveillance state.
And use of the Espionage Act to silence whistleblowers.
And not punishing war criminals.
Record numbers on food stamps are at least partly to do with an expansion of the program.
ISIS was created as a fallout from Bush and Blair's Iraq War (the clue is in the second 'I')
Tax rates for high earners and corporations are slashed by loopholes (21% for corporations)
Medical insurance costs have been increasing exponentially for a long time, Obamacare actually puts a cap on it in a like-for-like comparison of coverage.
Net illegal immigration was negative under Obama!
Gun-related homicides have been on a steep decline since the mid-90's, is there some reason you focussed on inner-city? Is it because you care for the ethnic minorities living there?
@RobertLongshaft -- It's a pity - and rather revealing - you needed to devalue your otherwise rational discourse with that childish "Barry" slur. Otherwise you might have provided food for thought. Still, just as well that uppity chap is around to blame for everything, isn't it ?
Calling Barack - Barry is no slur. He called himself Barry until he realised it wasn't a great name to use to get into women's knickers
People really need to understand who this man was and is.
Barry Obama is America's Tony Blair. Elected in the belief he would change things for the working man but in reality he only served to make himself unbelievably rich by servicing his bilderberg group paymasters.
"Barry Obama is America's Tony Blair. Elected in the belief he would change things for the working man but in reality he only served to make himself unbelievably rich by servicing his bilderberg group paymasters."
That bit's largely true. God alone knows why you think Trump is doing a good job, though.
Thank you for the excellent post, and don't mind the down votes. These are just poor people, whose brains got damaged by decades of liberal/leftist propaganda.
Trump has been sent by God to save us from the liberal destruction.
Listening to all these lefties, one would think the rest of the world, and specially Britain must be a paradise, where everyone drives a Mercedes and gas is cheap, since they don't have Trump.
Somehow that assertion seems doubtful, where the US economy shows real growth, Europe can only save itself by the money press of the ECB until Germany gets its act together and stops the charade.
Apple is not the only company repatriating dollars there will be many others. Today's the day when China start the petro-yuan which will reduce the demand for dollars outside the USA. So this very large number of dollars which used to be outside the USA, but are soon to be inside, what will effect will that have?
The dollar moves in response to market expectations of growth and the Fed interest rate policy. So neither of those has changed, so I doubt the dollar will change at all.
I have read in the FT that appetite for Treasury bonds is falling, so financing the national debt will get more expensive. That is unrelated to this Apple news however.
"Apple’s announcement also explained it will use lots of the cash in the USA on things like a new tech support center that will contribute to 20,000 new hires it plans to make in the Land of the Free. It’s also promised to build another campus somewhere in America, given its staff a $2,500 bous and tossed another $4bn into the fund it’s using to help US manufacturers innovate."
I'd have thought those were business expenses to be set against tax. Couldn't they have done that without any tax liability at any time?
I believe one other consequence of this is that Apple and other US companies will be given an incentive to pay taxes on revenue generated overseas as they will no longer be expected to pay US taxes on that taxed overseas revenue. So in the future Apple will probably declare more taxes in places like Ireland, and as they will get a credit on what the EU claimed that they owed Ireland they may go ahead and pay it as it at 12.5% represents less than what they'd have had to to the US on the same revenue and that revenue would no longer be liable for US taxes.
I dreamt last night that I was advising Trump on what smart watch to get. I suggested one that works with his appointment calendars and planners. But I guess he would just get an Apple Watch?
In the end of the dream, Trump just did what he always does... whatever he wanted at complete disregard for all advice given.
Yes, I have the "best" dreams.
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