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Old 12-10-2016, 02:02 PM
 
Location: New York Area
35,070 posts, read 17,014,369 times
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Quote:
Originally Posted by TaxPhd View Post
It's a rather perverse tax system that taxes two companies fundamentally differently if one is a US company and the other is a foreign company operating in the US, but are equal in all other respects. An inversion is simply a rational response to that perverse system.
I know, I know.

I want inversions made impossible. Or have the IRS attack them on grounds of pure tax evasion intention without economic substance, the same way they periodically attack tax shelters.
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Old 12-10-2016, 03:47 PM
 
50,795 posts, read 36,486,545 times
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Quote:
Originally Posted by censusdata View Post
My wife and I used a self order kiosk for the first time ever at Panera today. Worked great, avoided a long line and order was exactly how it was supposed to be. I worked fast food as a teen and we spent a ton of time fixing messed up orders.
I used to be a driver at Dominoes, back when they first opened, the Wild West days when it was guaranteed at your door in 30 minutes from the time you called or you got it free. There were many Friday nights (by far our busiest night) where they would mess up a lot of pizzas, put all mushrooms instead of half or something, have to remake it, and the manager would throw it to me with 6 minutes left to get it to the person's door halfway across town, and yell "Go, Go, GO!!!" It didn't help that a lot of people tried to trick us into being late by putting tape over their house numbers or turning out the outside lights at night.

It was actually kind of fun, but that's one reason why they had to stop the promotion, teen drivers were killing themselves racing to deliver pizzas against the clock and other people and parents were suing.

There weren't any real consequences for a late pizza unless it was frequent (actually it was better because we got a bigger tip) but it was a point of pride among the drivers, like a competition for who had the best record at the end of the night.


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Old 12-10-2016, 03:54 PM
 
10,755 posts, read 5,672,124 times
Reputation: 10879
Quote:
Originally Posted by jbgusa View Post
I know, I know.

I want inversions made impossible. Or have the IRS attack them on grounds of pure tax evasion intention without economic substance, the same way they periodically attack tax shelters.
The tax evasion angle won't work, because it isn't tax evasion. It is perfectly legal.

Do you really want a system that can hold company's hostage and force them to stay in the US? A much better plan is tax reform that would render inversions unnecessary.
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Old 12-10-2016, 03:55 PM
 
10,755 posts, read 5,672,124 times
Reputation: 10879
Quote:
Originally Posted by ocnjgirl View Post
I used to be a driver at Dominoes, back when they first opened, the Wild West days when it was guaranteed at your door in 30 minutes from the time you called or you got it free. There were many Friday nights (by far our busiest night) where they would mess up a lot of pizzas, put all mushrooms instead of half or something, have to remake it, and the manager would throw it to me with 6 minutes left to get it to the person's door halfway across town, and yell "Go, Go, GO!!!" It didn't help that a lot of people tried to trick us into being late by putting tape over their house numbers or turning out the outside lights at night.

It was actually kind of fun, but that's one reason why they had to stop the promotion, teen drivers were killing themselves racing to deliver pizzas against the clock and other people and parents were suing.

There weren't any real consequences for a late pizza unless it was frequent (actually it was better because we got a bigger tip) but it was a point of pride among the drivers, like a competition for who had the best record at the end of the night.


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Just curious, but what is this tagline that is in so many of your posts?

Quote:
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Old 12-10-2016, 10:38 PM
 
9,891 posts, read 11,766,452 times
Reputation: 22087
Quote:
Walgreen Co. is the nation’s largest pharmacy retailer with 8,200 stores
and locations in all 50 states. It is America’s drugstore, and Walgreens
pharmacies play a key role in providing healthcare to our communities.
Yet Walgreens recently stated that it may soon renounce its American
“corporate citizenship” by offshoring its place of incorporation to Switzerland, a tax haven.
The reason for doing this is clear: to avoid paying its fair share of taxes. (The drug maker
Pfizer recently made headlines by pursuing a similar reincorporation with AstraZeneca in
Great Britain for the same tax purpose.)
This reincorporation would take place primarily on paper – essentially a change of its
corporate address. In all likelihood, Walgreens would not move its headquarters,
employees or supply chains to Switzerland. But it could cost U.S. taxpayers $4 billion over
five years, leaving other businesses and American families to pick up the tab.

This tax maneuver is made possible by a loophole that allows American companies to
reincorporate offshore, typically in a tax haven, when just 20% of its stock is owned outside
of the United States.
Question: Why would an American company move their address overseas for tax reasons.

I once in 1977 spent 10 days in the Grand Cayman Islands, where a lot of companies have moved to. I was there for a conference on moving companies and starting companies with their head office in Grand Cayman Islands. If you go to law offices there, you will see name plates on their doors, of companies they have set up headquarters for on the outside of their office. The official taxable headquarters are in George Town Grand Cayman Islands, with a name plate on the door, and lawyers and staff are the ones at the corporate headquarters. They are required to hold a management meeting every year in the Grand Cayman Islands to do this. They can pay the lawyers to hold the meeting for them for a very reasonable fee. Or they can send several big shots to the Grand Cayman Islands to hold the meeting, and except for a very few minutes they are down there on a tax deductible vacation for a week or so. Real nice place to spend a week. Nice tourist facilities, beautiful beaches, great things to do on a relaxed tropical island resorts.

The American corporate tax rate is 35% or so for large companies. In other first line industrialized countries, it is 15% or less. American companies have to charge a lot more for their products, etc., if their company is in U.S. than it does moving overseas.

To greatly reduce the number of jobs shipped overseas, all that has to be done is to lower the Corporate Tax rate down to what other countries tax the companies located in their country. They do this, because it is often the only way they can compete with foreign companies and be profitable. The tax code and regulations literally drive companies overseas. Just think Apple has Billions of dollars of profit sitting in the Grand Caymans, tax free.

There are also a lot of regulations and hoops to jump through to build a factory in the U.S. A good example is Tesla Automotive which needs a new battery plant to build batteries for their next group of cars. It will hire thousands of people. They needed to be up and running in 18 months. If they built the plant in California, it would take 18 months and millions of dollars to get the permits they needed, and another 18 months to build and start up the plant. By putting their new factory in Nevada just outside of Reno, they could get the permits in days (just as clean and as safe plant as if they built it in California), and in 18 months from that date they announced it (months ago), the batteries will be used to power the next generation of Tesla electric cars.

Between tax laws, and regulations, companies are moving out of the country right and left, and or moving out of over regulated states such as California at the least.

Forbes Magazine has named the Caymans the World's friendliest Country.

http://www.caymanislands.ky/aboutcay...andcayman.aspx

Last edited by oldtrader; 12-10-2016 at 10:46 PM..
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Old 12-10-2016, 10:44 PM
 
10,755 posts, read 5,672,124 times
Reputation: 10879
Quote:
Originally Posted by oldtrader View Post
Question: Why would an American company move their address overseas for tax reasons.

I once in 1977 spent 10 days in the Grand Cayman Islands, where a lot of companies have moved to. I was there for a conference on moving companies and starting companies with their head office in Grand Cayman Islands. If you go to law offices there, you will see name plates on their doors, of companies they have set up headquarters for on the outside of their office. The official taxable headquarters are in George Town Grand Cayman Islands, with a name plate on the door, and lawyers and staff are the ones at the corporate headquarters. They are required to hold a management meeting every year in the Grand Cayman Islands to do this. They can pay the lawyers to hold the meeting for them for a very reasonable fee. Or they can send several big shots to the Grand Cayman Islands to hold the meeting, and except for a very few minutes they are down there on a tax deductible vacation for a week or so. Real nice place to spend a week. Nice tourist facilities, beautiful beaches, great things to do on a relaxed tropical island resorts.

The American corporate tax rate is 35% or so for large companies. In other first line industrialized countries, it is 15% or less. American companies have to charge a lot more for their products, etc., if their company is in U.S. than it does moving overseas.

To greatly reduce the number of jobs shipped overseas, all that has to be done is to lower the Corporate Tax rate down to what other countries tax the companies located in their country. They do this, because it is often the only way they can compete with foreign companies and be profitable. The tax code and regulations literally drive companies overseas. Just think Apple has Billions of dollars of profit sitting in the Grand Caymans, tax free.

There are also a lot of regulations and hoops to jump through to build a factory in the U.S. A good example is Tesla Automotive which needs a new battery plant to build batteries for their next group of cars. It will hire thousands of people. They needed to be up and running in 18 months. If they built the plant in California, it would take 18 months and millions of dollars to get the permits they needed, and another 18 months to build and start up the plant. By putting their new factory in Nevada just outside of Reno, they could get the permits in days (just as clean and as safe plant as if they built it in California), and in 18 months from that date they announced it (months ago), the batteries will be used to power the next generation of Tesla electric cars.

Between tax laws, and regulations, companies are moving out of the country right and left, and or moving out of over regulated states such as California at the least.
It isn't so much the tax rate that is driving inversions - it's that the US assesses tax on world-wide income for domestic corporations.

Last edited by TaxPhd; 12-10-2016 at 11:16 PM..
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Old 12-10-2016, 11:12 PM
 
Location: Living rent free in your head
42,850 posts, read 26,275,432 times
Reputation: 34059
Quote:
Originally Posted by oldtrader View Post
There are also a lot of regulations and hoops to jump through to build a factory in the U.S. A good example is Tesla Automotive which needs a new battery plant to build batteries for their next group of cars. It will hire thousands of people. They needed to be up and running in 18 months. If they built the plant in California, it would take 18 months and millions of dollars to get the permits they needed, and another 18 months to build and start up the plant. By putting their new factory in Nevada just outside of Reno, they could get the permits in days (just as clean and as safe plant as if they built it in California), and in 18 months from that date they announced it (months ago), the batteries will be used to power the next generation of Tesla electric cars.
That's not exactly right...Tesla complained that part of the issue they had with California was the regulatory process, so with Musk's input California wrote new legislation to streamline the regulatory process. But in the end, California "only" offered 500 million in incentives as opposed to the 1.25 billion Nevada offered.

I'm not going to source this for you because there are numerous articles about it online. I lived in Reno at the time and followed the whole thing on local news.
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Old 12-11-2016, 08:05 AM
 
50,795 posts, read 36,486,545 times
Reputation: 76590
Quote:
Originally Posted by TaxPhd View Post
Just curious, but what is this tagline that is in so many of your posts?
I don't know. It started leaving that every time I edited a post and I don't know why. I asked once in a thread but no one answered. It's the same computer and same browser I've always used but it didn't start happening until fairly recently.
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Old 12-11-2016, 09:19 AM
 
Location: City Data Land
17,155 posts, read 12,962,522 times
Reputation: 33185
Quote:
Originally Posted by 2sleepy View Post
I find almost nothing to be cheaper on ebay unless it's used. Not to say that Amazon is always the cheapest, but unless there's a large price differential I won't use ebay as an alternative place to shop...to much uncertainty about when the item will ship, what you will actually get and how difficult it might be to return the item. I usually price compare Amazon with Target, Macy's, Best Buy, ToysRus etc. all three are easy to do business with and frequently offer free shipping.
It must be differences in what people buy then. Most of the items I shop for online are cheaper on eBay. Sellers usually ship out the next day. But I am addicted to my Kindle. I don't buy bestsellers on it. I refuse to pay more for a Kindle book than a paper book. I get a lot of cheap Kindle books from the independent authors. I've found a lot of hidden gems from unknown authors. But I've even gotten ebooks on ebay as well. I got Stephen King's entire collection for $9, then just uploaded it to my Kindle using Calibre. I also got all of David Baldacci and Lincoln Child/Douglas Preston's works super cheap too.
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Old 12-11-2016, 01:52 PM
 
8,299 posts, read 3,812,442 times
Reputation: 5919
Automation Can Actually Create More Jobs - WSJ
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