But they do have to prove they've lost money as a result. Maybe they have too - but it ain't proven yet, is it, as they've not yet had a down round.....
1348 posts • joined 12 Feb 2008
But they do have to prove they've lost money as a result. Maybe they have too - but it ain't proven yet, is it, as they've not yet had a down round.....
"On the Soviet side, the communist state was so paranoid that earlier that month it had shot down a Korean passenger jet that had accidentally wandered into Soviet airspace,"
I spent a decade as the business partner of the nephew of the bloke who ordered that. Mixed bag, Soviet military types.....
They're offering some £9.15 an hour more than most of the media competition.....
Personally I'd have a look through her campaign funding to see which anti-virus company is paying for this.
I think I actually said every fraud, scam, and mistake.
Been there since long before my labour was liberated from here.
And there's axes to grind and simple facts. Apple borrows inside the US in order to pay dividends and buy back stock. This means it does not have to repatriate foreign profits and then pay US corporate income tax to do so.
As to whether this is a good idea or not that can be axe grinding. But the simple facts are just that, the simple facts.
Pay varying as a result of life choices is an interesting definition of unfairness.
That I understand words rather than code is obviously unfair given that freelance journos don't earn like coders perhaps? Or is it only unfair if it's because I chose this route?
The two are using different definitions. DoL tends to think that pay should be the same for roughly similar positions. Google for the same positions. Thus both can be right by their own definitions.
So, managers should get paid the same, right? HR managers should be paid the same as coding managers? Well, umm.....OK, managers of those overseeing the Goog Algo itself should get paid the same as the manager of the Doodles? Err, well, ......OK, so managers of Python coders, the managers with the same education, experience and place of work, should be paid the same, regardless of gender (or melanin content, who they try to pick up on date night etc)?
Roughly speaking mind, the DoL is towards the beginning of that cry for equal pay, Google towards the end. Who you think is right about what equal pay should mean is up to you but that is where the argument is.
The interesting question is what is going to be defined as fake news?
For example, someone claiming that global inequality is increasing. Nope, it ain't, it's falling. Poverty increasing in UK? Nope, relative poverty is, that's inequality, is. Global inequality is falling, within country is rising.
Equally, globalisation only benefits the rich.....nope, the great gainers have been the global poor.
Companies must pay more tax! Companies never carry the burden of any tax.
And so on and so on. A true scrubbing of fake news would produce a very, very, different media.....doubt it will happen though.
before reading it can be put to a plethora of uses .. lining for kitty litter, firelighters, mopping up old sump oil ...
Well, I wouldn't say that I'd specifically go out to get phones to recycle them for the gold. But there are people who do mine them and do so productively.
There're a couple of caveats though.
1) No one metal makes the process worthwhile. If you were doing 80s PCs with 200 nm Au plating on the pins them maybe that would be enough in revenue. And if anyone's got some old analogue telephone switches then it's worth hand clipping them for the gold content (have actually watched this being done).
For modern equipment you want the Sn, Cu, Au out and maybe they'll just about cover your costs. Add in not paying Landfill Tax and you're about there.
It might be possible to go further, take the Ta out, but not much more.
2) The other side of this is what are you allowed to throw away? If, once you've started mulching stuff this becomes chemicals waste or some such, with higher disposal costs, you might well find that landfilling the original phones makes more sense.
It's a delicate balance between the two, revenue and final disposal costs. Can go either way dependent.
What certainly doesn't get paid for is the cost of collecting widely dispersed waste into one place. Paying for that has to come from elsewhere. Could be like this. Or, the people who collect today usually try out those that still work and sell them in poor countries. That's the extra revenue that makes the whole system work. Just recycling for the metals costs will not and cannot pay for the costs of the whole system, including collection.
The specific agreement that Microsoft has with HMRC is an "advance pricing agreement."
In layman's terms this is M asking HMRC "Iz we obeying the law?" and HMRC sending back a letter saying "As far as we can see, yes."
This is not an outrage.
No, sorry, not true.
I'm sure someone or other has written an article about it around here too.
Male market working hours have fallen substantially, female market working hours have risen. Male household working hours have fallen, female household working hours have fallen substantially.
Leisure hours for men and women have risen strongly over the past century.
That Keynes and only working 15 hours a week thing has in fact happened. It's the household working hours that have fallen.
"Under capitalism, technological progress results in more products, not in more leisure. Factories that improve their efficiency don’t shut down and send workers home early – workers keep the same hours and crank out more goods."
Oddly, the most remarkable change in human life over the past couple of centuries of capitalism has been the massive expansion of leisure time.
The reason being that as we get richer we take some part of our greater wealth as more leisure. The substitution effect.
But then that's what you get when you've philosophers trying to do economics.
What with given the past here and the present at Forbes. However:
"Forbes also only included companies that had more than seven years' worth of public financial data and a market value of over $10bn – thereby removing 99 per cent of the companies that do the bulk of the innovation in the world."
That last isn't really quite right. In economic terms we try to make a distinction between invention and innovation. The first is the creation of some new thing. The second is the general improvement of some thing through multiple iterations.
Small companies are generally more inventive than large. And large generally more innovative than small.
"Another couple of millennia and they might be reliable."
It was specifically noted that the deal freed Google from the future problem of the diverted profits tax. On hte basis that they're not diverting profits.
Which is that the Google Tax hasn't worked in the UK. Not even on Google.....that recent tax deal was absolutely nothing to do with the diverted profits tax and actually, the settlement itself frees Google from the diverted profits tax.
The reason to send HEU to the US is because they have a system, built and in place, to blend it down to LEU suitable for use in reactors. This is one of the (few?) things that Al Gore got right. Get that HEU out of Russia and into US reactors and spend however much money necessary to do so.
You do not use HEU is energy production reactors although you might, just, use it in one or another design of isotope production reactors.
And yet the US has been driving a worldwide campaign to get people to stop using HEU for medical isotope production because of those proliferation issues. To the point that they will come in and build an LEU using production reactor and even finance it.
Thus, HEU goes off to the US, the US then supplies back LEU suitable for isotope production.
It all entirely makes sense. But of course someone at The Conversation who wanted to complain about nuclear waste, an entirely different subject, wouldn't bother to tell you all that.
How would anyone know without trying it?
My career, such as it was, in tech journalism was entirely untroubled by ejaculate covered images of myself. Clearly no popularity at all among gay men or girls who gush.
However, there is a bit that I don't understand here. We don't have to get entirely all Simon Baron Cohen here but the tech industry is rather heavy on the "nerd" sector of the population. Nerd having two slightly different meanings at times, one "interested in tech and engineering" and one "not all that good at social interaction". The bit I'm not getting being why is there all this vocality about the sector "tech and engineering" being full of people "not very good at social interaction"?
It's rather one of those things that goes with the territory, isn't it? Like complaining that man sheds don't come with lace doilies, or that the graduate students in French Romance poetry don't seem to be very good at maths.
Admittedly, I do get easily confused. I recall a very pretty young Randian Objectivist insisting that one of the joys of the philosophy was that it allowed her, nay encouraged her, to have decent sex when- and where- ever. OK, fine by me, but why did she get very pissed off when I made a pass at her?
It's not quite as exciting as all that. UK based salesmen closing deals with UK customers always would be a "permanent establishment" in the UK and the profits from such would always be subject to UK corporation tax.
So, what they're saying is that "our large customer salesmen are based in the UK". Everything else flows from that.
Including, funnily enough, that Facebook UK will now be paying royalties to Facebook Ireland. Because tax is indeed levied where the economic activity takes place and some good part of Facebook's economic activity is all that development work done in California. Meaning that, under those usual tax laws, Facebook UK *must* pay a royalty from that UK income. And that royalty moves through Ireland, to Bermuda and then, maybe yes, maybe no, into the US.
What the net effect of this will be is going to be interesting. I can see the tax bill rising, yes, but I wouldn't expect it to be by all that much.
Buy an MSP?
Hmm, Members of the Scottish Parliament are pretty cheap but I'm not sure what I would do with one....porridge tester perhaps?
I'm thinking of it more as a way to advertise an agency that does magento. But everyone's warnings much appreciated: and once they've been made I can see the relevance of them too.
The current project is much more fun: mapping tornado damage for FEMA in a Ruby/Rails system.
Care to drop me a line about this? I think the email attached to my pieces here still works. If not, timworstallAT"taxdodger"gmail.com does.
I'm looking around for an entry level service that we might offer (me and my team of Czechs) and this is the second Magento problem I've seen in a couple of months.
"We patch your Magento system for $20" might be something we could usefully do. Or some other similar sort of price. Would love to get some guidance from those who know whether that's something that might fly.
Not quite, no:
"What you quote them as saying here is that, given that the current tax system is based on taxing corporations on the profits they make in this country,"
I effectively call them idiots because that is *not* how the tax system currently works yet they are claiming it does.
"transfer pricing to transfer profits across borders is illegal."
"but they've been curiously uncurious when it comes to investigating Google's trading arrangements, or Starbucks' bean purchasing."
Nope. Starbucks first. They paid a margin of 20% on the cost of beans to their own subsidiary in Switzerland. Note that beans are cheap, maybe 5 p on a cappuccino.
So, what do the transfer pricing rules say? That a company must make sure that trade between two subsidiaries happens at market prices. That is, no special prices, no deal, to move money around in order to shift profits.
So, do you know any coffee bean brokers who are willing to buy, grade, sort, store, coffee beans with out being paid a margin to do so? Quite: so Starbucks *must* under transfer pricing rules pay some sort of margin to its Swiss subsidiary. Maybe 20% is too much. But for them *not* to pay a margin would be a breach of the transfer pricing rules.
Google is differently to do with the transfer pricing rules. The sales are made into the UK by Google Eire. That's Ireland's money, nothing to do with the UK. EU law that is, any EU company may sell anywhere in the EU and pay tax in whichever jurisdiction it calls home.
If Google had no office at all in the UK there would be no argument over this at all.
Google does have an office in the UK. The argument is not over the ad revenue again. It's over how much Google Eire pays Google UK for their engineering services and support. HMRC is saying that proper arms length transfer pricing would include a bit more margin for Google UK. Google has grudgingly agreed.
It's absolutely not about the ad revenue at all.
Now, maybe the law should be different and maybe it shouldn't be but that is the argument within the law as it is today.
Finally, the idea that the big boys get special treatment. Err, no. The loophole that is being exploited here is one that is available to every small company. I've used it myself, multiple times. So, I sell some Ruby/Rails programming services into the US from the Czech Republic, as I just have done. US revenue from US customer. Should I now file a US tax return, pay US taxes? Nope, I'm a small company, I don't have a base in the US. So, to keep the world simple, to allow small companies to actually export, Aw, Heck, just pay the tax at home, to the CR.
*That* is what Google is doing, exploiting the permanent establishment rules put into the law to *aid small companies*. And every small company that does export is doing exactly the same thing.
I do the insult indirect to Murphy and Sikka. Up above Andrew has gone for the insult direct: "innumerati".
And you want to shout at me about it?
I haven't actually said the employees should be taxed the equivalent. Rather, I've said that the economic incidence of corporation tax is upon 1) The shareholders in the company being taxed and 2) All the workers in the economy applying the corporation tax.
It is a basic and known economic finding that the corporation, as a corporation, does not bear the economic cost of the tax: only people can do that. So, instead of taxing the corporation why not just tax people instead? Comes to the same thing in the end but it's rather easier to just tax people: as this story is showing.
It really depends upon the specific item under discussion. Ores can be identified pretty well by location. Not isotopes, but trace elements can be tracked and each ore body is different.
But the real problem is then processing. If you've something where artisanal processing is possible (say, gold or tin) then you have no hope at all of being able to track material. OK, I can't do it but it can be done, to make metallic tin out of cassiterite with a bunch of rock, some charcoal and some cheap labour. Might not be all that efficient but it would get you something pure enough that a scrap merchant would buy it. Same is true of gold. And once you've got something that can be sold to a scrappie then of course there's just no manner at all of tracking it.
Tantalum is rather different. You've only got 15 or so plants around the world that can possibly process the ore. Requires HF, which just isn't something that is going to be handled in an artisanal manner.
Control or not control is something that depends upon the details of the specific technology of that mineral.
Don't actually know enough about cobalt to know which way that one goes.
No, he wasn't......
The actual suggestion that AI will make soon enough is that Co should be added to the W, Sn, Ta and Au restrictions. That Blood in the Mobile stuff.
The problem with this, as in El Reg passim, is that it's a grossly expensive and ineffective way of doing it. It cost US corporations (and US listed corporations *only*) $4 billion to bring in the last set of regulations and processes. To no very great effect that anyone can see.
Face masks and a bit of education on shoring up mine workings would appear to be both cheaper and more effective.
Well, the Starbucks and Fiat cases were about Luxembourg and meant €20 and €30 million in tax respectively.
The €750 million one in in Belgium and is for 35 companies over 10 years: about €2 million each.
This is all nibbling around the edge of the tax system, not undermining the basic principles. And Bloomberg here is appallingly wrong.
Their basic method of calculation is as follows: we've heard that Apple's going to lose that EU case. OK, so, what would be Ireland tax on all Apple's overseas profit: $8 billion.
But that's to miss what the EU case is about. It simply isn't about the Double Irish, nor the way that IP rights are held in Bermuda. And it's that which makes Apple's tax bill so low. Profits pile up in Ireland, the Bermuda company then says you must pay for the IP and off the money goes.
This isn't being challenged, it's not being investigated and the EU has no power over it anyway.
What is being investigated is some minor issues over how Apple's profits made from actually working in Ireland are calculated. Best informed guess is that, if they lose, bill of maybe €200 million to cover a decade.
Bloomberg seriously misfired on this one.
There will be no penalties. Because it's a "state aid" case. Meaning that whoever has done something wrong it's the government, not the company.
Can't see it working for me really.
Given past decades of experience the idea that there's two people, simultaneously, on the planet who desire to have sex with me is difficult to believe. That there's two or more simultaneously who desire to do so simultaneously.....
Lewis, I don't know I'm afraid. Seen some stuff in the Telegraph from him. I'm at Forbes, as I ever was, plus there's my blog at myname.com
Snigger, yes, that is very amusing. But I think Gordon 10 has it right there, it's the end of the Weekend Edition.
There's also an amusing difference between the active and passive to be noted, between "were moved on" and "decided to move on".
Have to admit to being a bit mystified here.
One of two things has happened. Apple has screwed up the paperwork. Or Italy is over turning the standard international taxation order. Need more detail of what actually happened before working out which.
Did some pencil sketch numbers about running a Kickstarter to produce an alt-mag. Just couldn't see 10k people chipping in $100 each to give a two year run at doing it properly. Just not on. And as for trying to do it commercially.....have you seen ad rates these days?
That is indeed exactly how it works.
Thank you for that.
And the Worstall response here would be to use the word "elastic" in its economic sense. Nothing is infinitely elastic nor inelastic. Everything sits on the spectrum of elasticity.
And cloud supply is obviously more elastic than dedicated supply of computer cycles.
At which point, well, yes?
Worstall no longer writes a weekend column for El Reg. Thus there's nothing missing.
And just to make my, Worstall's, opinion of this clear. El Ed has an absolute right to deploy his resources, his freelance budget, as he sees fit. I thoroughly enjoyed writing for y'all and also have no complaint whatsoever about El Ed deciding it's something that didn't quite work out as perhaps hoped.
Hmm, dunno. A quick search for "alumina in glass" brings up, first page, a paper from 1947. So it's not exactly a new idea. It's the method to get a high alumina glass, not alumina glass, which is new.
My problem here is that David Walker is the name of the husband of Polly Toynbee.
Got me very confused, that did,
I'm glad I was able to engage your interest.
But then they already are on AIM anyway.
Globo anyone? Sino-Forest? (Not AIM but still). And that telecoms one from last year? Quindell.....not a scam but "interesting" all the same.
Sad creature that I am I bothered to look up their numbers.
An 18% rise in the risk of colorectal cancer.
From perhaps 50 cases per year per 100,000 people to 60 cases per year per 100,000 people.
Not exactly the terror of the worlds that some newspapers seem to think it is.
Economics at university these days. Lots and lots of mathematics to feed the macro models. Got to be done but that's the very boring part of the subject. There will be lots of mandatory courses in all that stuff. For enjoyment, tell her she might want to sample, as her electives, bits of political economy, micro theory, public choice, anyone who is teaching Mancur Olson and so on. Even a light introduction to Marx can be fun (but don't go the whole hog and actually believe it).
And there will be lots of statistics. But make sure that you understand the underlying concepts, not just the manipulations. Because much fun (for an odd value of "fun") can be had by reading the various pressure group reports and seeing how they've ignored those basic concepts in constructing their numbers for public consumption.
Called the "wealth effect". We think we're wealthier, we spend more. We think we're poorer, we spend less.
Is why there was going to be a recession in the US whatever happened to hte banks: $8 trillion in housing wealth was lost.
Umm, sorry about this but couldn't resist.
If you've two of them does that mean you need both hands to find them?
That would actually make a good column of this type. Jean Tirole and dual facing markets and all that. Often that would be the genesis of one of these. A comment, some pondering (as I did while trotting the dog around the Portuguese countryside just now) and then a few notes....and then I find I'm late for the pub but the article has been filed a week early. The subs loved that.
I shall be on time for the pub today though.
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