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Old 12-18-2017, 08:55 AM
 
Location: Fairfax County, VA
1,387 posts, read 601,896 times
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Quote:
Originally Posted by GreggT View Post
That being said knowing the top 1% pay 40% of all income taxes, the bottom 50% pay Zip, how can these bottom 50% get a tax cut...
Your numbers are wrong, there are many taxes other than federal income tax, and you need to bone up on refundable tax credits.
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Old 01-18-2018, 10:26 AM
 
6,997 posts, read 6,635,326 times
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Apple had the money in a US Citigroup account and merely transferred the funds to the parent firm from the Irish shell company

Apple Transfers $252 Billion in Citigroup Account from Irish Subsidiary to Parent Company | Beat the Press | Blogs | Publications | The Center for Economic and Policy Research

The repatriation tax touted by Apple iappears to be calculated by simply multiplying the accumulated 'overseas' profits estimated at 252 billion dollars by the tax rate of 14.5 percent on cash-equivalents. If it's held in Apple stock or other assets, it would be taxed at 7.5 percent. Apple will also get a tax writeoff at the normal corporate tax rate of 21 percent for any deductible expenses, such as the contribution of Apple stock grants to employee bonuses or pension plans. In all likelihood, the tax paid will be much lower.

Last edited by lchoro; 01-18-2018 at 11:52 AM..
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Old 01-18-2018, 10:39 AM
 
8,285 posts, read 3,456,454 times
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https://www.marketwatch.com/story/ap...ash-2018-01-17
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Old 01-19-2018, 08:52 AM
 
2,240 posts, read 1,388,386 times
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Quote:
Originally Posted by lchoro View Post
Apple had the money in a US Citigroup account and merely transferred the funds to the parent firm from the Irish shell company

Apple Transfers $252 Billion in Citigroup Account from Irish Subsidiary to Parent Company | Beat the Press | Blogs | Publications | The Center for Economic and Policy Research

The repatriation tax touted by Apple iappears to be calculated by simply multiplying the accumulated 'overseas' profits estimated at 252 billion dollars by the tax rate of 14.5 percent on cash-equivalents. If it's held in Apple stock or other assets, it would be taxed at 7.5 percent. Apple will also get a tax writeoff at the normal corporate tax rate of 21 percent for any deductible expenses, such as the contribution of Apple stock grants to employee bonuses or pension plans. In all likelihood, the tax paid will be much lower.

Good one.

As someone who just spent the better part of the last month+ working on a repatriation calculation for one of the largest corporations in the world, I can assure you it's not done "simply" by multiplying a balance.

As far as the rest of that ridiculous "article", the forced repatriation is a higher tax than they would have paid under the old system....considering the money was permanently reinvested overseas and already paid foreign tax.....the deferral of US taxes on worldwide income was NEVER going to be paid because no one would be dumb enough to bring it back to be taxed a SECOND TIME at a marginal 35% rate. It was deferred forever basically.

The toll charge, marks the shift from worldwide taxation to territorial and allows the U.s to hit those FOREIGN earning with a one time charge.
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Old 01-19-2018, 08:55 AM
 
2,240 posts, read 1,388,386 times
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Quote:
Originally Posted by Hoonose View Post
Why would you expect that they would bring all of the cash back from overseas?

It was already permanently reinvested internationally, and the U.s operation was fine without it. If they needed funding for additional capital in the US, they would have already borrowed it or funded it domestically.

It's not like all of the sudden just because the U.s imposed a toll charge, that Apple has a need to blow through billions on new capital in the US.
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Old 01-19-2018, 09:01 AM
 
8,285 posts, read 3,456,454 times
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Quote:
Originally Posted by Thatsright19 View Post
Why would you expect that they would bring all of the cash back from overseas?

It was already permanently reinvested internationally, and the U.s operation was fine without it. If they needed funding for additional capital in the US, they would have already borrowed it or funded it domestically.

It's not like all of the sudden just because the U.s imposed a toll charge, that Apple has a need to blow through billions on new capital in the US.
I wouldn't.
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Old 01-19-2018, 09:05 AM
 
2,240 posts, read 1,388,386 times
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Quote:
Originally Posted by Hoonose View Post
I wouldn't.
I guess I don’t mean you specifically. I just read these ridiculously ignorant articles and people have this shock and outrage that “omg apple isn’t going to make jobs float from the sky and pave American strreets in gold”.

It’s just kind of funny.
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Old 01-19-2018, 09:16 AM
 
8,285 posts, read 3,456,454 times
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Quote:
Originally Posted by Thatsright19 View Post
I guess I don’t mean you specifically. I just read these ridiculously ignorant articles and people have this shock and outrage that “omg apple isn’t going to make jobs float from the sky and pave American strreets in gold”.

It’s just kind of funny.
It is the be all and end all if one is partisan.
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Old 01-23-2018, 09:07 AM
 
6,997 posts, read 6,635,326 times
Reputation: 5274
Quote:
Originally Posted by Thatsright19 View Post
Good one.

As someone who just spent the better part of the last month+ working on a repatriation calculation for one of the largest corporations in the world, I can assure you it's not done "simply" by multiplying a balance.

As far as the rest of that ridiculous "article", the forced repatriation is a higher tax than they would have paid under the old system....considering the money was permanently reinvested overseas and already paid foreign tax.....the deferral of US taxes on worldwide income was NEVER going to be paid because no one would be dumb enough to bring it back to be taxed a SECOND TIME at a marginal 35% rate. It was deferred forever basically.

The toll charge, marks the shift from worldwide taxation to territorial and allows the U.s to hit those FOREIGN earning with a one time charge.
There was no repatriation. There was no forced repatriation. It was an inter-company transfer between entities set up for the purpose of moving earnings around to minimize taxation with the help of the 2003 law.

For many of the companies, the earnings were artificially shifted from their domestic operations to a foreign corporate shell through a change in the corporate structure and transferring of licensing rights to that entity. Since the entity was located in a tax haven, such as Ireland, the foreign tax paid was negligible.

It was blackmail to force the corporate tax rate lower. They could refuse to pay the tax as long as the law stayed in effect.

Paul Ryan gets payoff for shepherding the tax change into law.

Paul Ryan Collected $500,000 In Koch Contributions Days After House Passed Tax Law

Last edited by lchoro; 01-23-2018 at 09:38 AM..
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Old 01-23-2018, 12:51 PM
 
2,240 posts, read 1,388,386 times
Reputation: 4894
Quote:
Originally Posted by lchoro View Post
There was no repatriation. There was no forced repatriation. It was an inter-company transfer between entities set up for the purpose of moving earnings around to minimize taxation with the help of the 2003 law.

For many of the companies, the earnings were artificially shifted from their domestic operations to a foreign corporate shell through a change in the corporate structure and transferring of licensing rights to that entity. Since the entity was located in a tax haven, such as Ireland, the foreign tax paid was negligible.

It was blackmail to force the corporate tax rate lower. They could refuse to pay the tax as long as the law stayed in effect.

Paul Ryan gets payoff for shepherding the tax change into law.

Paul Ryan Collected $500,000 In Koch Contributions Days After House Passed Tax Law
Let’s come back from fantasy land.


There was a toll charge, aka a one time forced repatriation.
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