Suck it up, boys. Pay your taxes like the rest of us. You're sitting on huge war chests of cash. You can afford to contribute a little bit of that to the common good.
US companies in general are sitting on $2Trillion in cash. Productivity is sky high, because of all the lay offs across the economy, and profits are generally up across the board in most sectors of the economy.
US companies aren't spending because they don't want to spend. They aren't hiring because they are productive enough and are profitable enough without hiring. They are also scared because of all the uncertainty in the financial sector, not necessarily because of the high taxes.
The few people that are actually putting money to work in this economy are angel investors and VC's by giving small engineering teams small amounts of cash as well as leeway to experiment at building interesting products.
> US companies aren't spending because they don't want to spend. They aren't hiring because they are productive enough and are profitable enough without hiring.
Companies spend more and hire more when it's necessary to meet additional demand. If there is no additional demand, then they don't. It's not because they don't want to spend or are content with existing profits, it's because consumer demand is currently very weak. With 40% of US mortgages underwater, it's going to take a while before consumer demand strengthens again.
And the consumer demand is very directly influenced by the job market. With so many people out of work. Many of us who do have jobs are cautious to not spend beyond our means. Its a vicious circle.
Of course the goal of a public company to make money I can't blame these guys to hoarde all the money they can. Thats what their shareholders and directors demand.
They have little reason to suck it up and pay these taxes. It's easy to book of shore 'profits' and with an occational tax holiday there is huge incentive to do so. Just create a a 'paperclip' in an offshore company and bill the US company 1billion for it and you get to avoid paying taxes what joy. Then wait a few years and bring that money home on a semi regular holiday.
PS: Or we could say on Dec 31 there will be a one time 50% tax on any money in offshore accounts and you can clean up this mess real quick with them quickly moving all that money back home.
They don't owe any taxes if they keep the money outside the country.
People tend to think of taxes like "skimming" off the top, and like some kind of inevitable thing that doesn't affect your decisions. But that is the wrong way to think about it: when taxes are high enough to have a significant impact, they do affect taxpayer decisions.
You seem to be saying that they should keep making decisions as if there were no taxes, and then pay high taxes because of those decisions. But that's completely unrealistic.
When taxes are higher than a trivial amount, the correct way to think about them is as policy that will have lots of effects; some obvious and some not obvious.
Exactly, taxes act as incentives and de-incentives.
Why do we have a health care system based on employer based insurance? Because employer based healthcare is tax deductible, and personal health care is not.
What effect does the home mortgage interest deduction, and home sale capital income tax holiday have on the price of houses -- they result in higher housing prices because they provide incentive for more leverage and reaching for the highest appreciation.
What is the result of the decision for us to tax personal income rather than personal consumption -- more consumption and less saving.
What we tax and how we tax it has a very real impact on behavior around that thing.
The long term effect of large amounts of cash overseas due to having a higher tax rate here is ultimately to build more operations overseas, to use it. That is how the incentive is set up.
Not a fan of a tax holiday, but am a fan of reducing that incentive by bringing our corporate rates lower.
We have employer based health insurance in the US because insurance works on a group level, not individual level, when the risk being insured is not under the control of the consumer.
We have employer-based health care, and transit subsidy, and meal subsidy, and all that crap, because of stupid tax laws, yes.
Google and many other companies route their overseas earnings to Bermuda through Ireland and Holland, and effectively pay 2.4% tax on that money since Bermuda doesn't have any corporate taxes: http://www.bloomberg.com/news/2010-10-21/google-2-4-rate-sho...
> Taxes are the price of civilization. Suck it up.
You forgot to show that the taxes that we pay go for said civilization. Some do, but the vast majority don't.
For example, the US govt spends, per capita, about the same as western european countries. None of the folks arguing for higher taxes would suggest that we're getting the same level of services. Since we're paying and not getting, it's unclear why things would change if we paid more.
BTW - The author of "Taxes are the price of civilization." also said "Three generations of imbiciles are enough." in a decision upholding forced sterilizations (of someone who probably wasn't an imbicile, but instead a victim of sexual abuse by a govt official). Progressives are like that....
Actually, levels of American taxation are amongst the lowest in the developed world.
Yes, and the ideological forebears of American conservatives today had a penchant for lynching people with a different skin colour. See how blanket statements are easy?
Back in the '20s people had a different perception of what is a reasonable thing to do to people. No Progressive today believes in eugenics, blah blah blah.
> Yes, and the ideological forebears of American conservatives today had a penchant for lynching people with a different skin colour.
Actually, they didn't - conservatives were driven out of the South after reconstruction by an alliance of southern democrats (who were populists) and progressives.
Jim Crow was instituted by Democrats and the progressives at the time applauded. Wilson thought that it was such a good idea that he segregated the US military....
Most of the votes for the civil rights acts came from Northern Repubs. The vast majority of the opposition came from Southern Dems. And, no, the Democrat party didn't repudiate them - they retired in good standing during the 70s.
That's why MLK was a Republican....
Yes, today's conservatives oppose affirmative action. Feel free to explain why poor white and asian kids should give up slots to middle class blacks.
>(And yes, tax revenue per capita is the correct thing to compare with benefits received.)
I'm more inclined towards Yglesias' counter argument in the second link, in that the US has plenty of room to raise taxation but that's a reasonably persuasive argument. As a Canadian, I still think Americans whine about their taxation rates a bit too much, but I suppose we have a better end of the deal.
>Actually, they didn't - conservatives were driven out of the South after reconstruction by an alliance of southern democrats (who were populists) and progressives
>The vast majority of the opposition came from Southern Dems.
Now you're mixing terms.
1) No one can speak for Progressives in the 1910s. For one, I am simply not informed enough but… I doubt anyone had a racially enlightened point of view at the time. More recent scientific developments have discredited the racial theories of the time and so everyone changed their mind.
2) You're being disingenuous. Being a Democrat does not mean you're progressive; look at the modern day Blue Dog Democrats. If they opposed civil rights, they were certainly not progressives.
> I'm more inclined towards Yglesias' counter argument in the second link, in that the US has plenty of room to raise taxation
Whether the US could have more revenue doesn't address my point that the US has sufficient revenue to satisfy the demands of folks asking for more revenue. Given that, it's unclear why more revenue would satisfy those demands.
The US govt spends more, per person, than does Canada, yet we get fewer benefits. When that changes, we can talk about more spending per person.
> I doubt anyone had a racially enlightened point of view at the time.
Based on what? Mark Twain certainly shows otherwise.
> If they opposed civil rights, they were certainly not progressives.
Sure they were. In fact, today's progressives claim them as their ancestors. Yes, including Wilson, Holmes, and Sanger.
> How are you seriously trying to pretend that these policies were the bastions of "progressives and their allies"?
I'm not pretending - it's the truth.
Bull Connor, the Birmingham, AL sheriff famous for firehosing civil rights demonstrators, was a prominent Democrat in AL and was a delegate to five Democratic National Conventions (1948, 1956, 1960, 1964, and 1968). He wasn't the exception - he was the rule.
I know who instituted Jim Crow and how the political alliances of the time worked. (Do you really think that Republicans had political power in Jim Crow south?) I also know who segegated the US military. I also know who wrote "Three generations of imbiciles are enough" in a Supreme Court decision upholding forced sterilization. I've also looked at who voted for and against the various civil rights acts in the 60s. I know that Davis-Bacon was intended to keep poor blacks from moving north and taking jobs from white union members.
In each case, it's Democrats in alliance with Progressives.
That's just for starters.
I note that you haven't bothered to cite anything more than outrage. Feel free to list two things that Repubs have done that compares to the elements of that list.
Republicans at the time weren't saints, but they were considerably better on race issues than Democrats and Progressives. That's why MLK was a republican.
It helps to pay attention instead of parroting dogma. For example, do you know what the "slaves count for 3/5 of a person" clause in the constitution is about and who wanted the number to be 1 and who wanted the number to be 0?
It's a clause for determining the number of representatives that a state gets in the House of Represenatives. The slave states wanted slaves to be counted as 1 while the not-slave states wanted slaves to not count at all. 1 gives the slave states more representatives while 0 gives them less....
Given that, would it be better for the number to be 1 or 0?
Hong Kong still has property taxes, payroll taxes, corporate income taxes and gambling taxes among a few others.
Pre-1913 America had a radically different view on what kinds of services the government should provide. Most of the US budget is split between Social Security, Medicare/aid and the Military.
I'll suck it up when the price I pay for civilization is the same as everyone else's.
I don't pay 10x as much as my neighbor for the same candy bar or cell phone plan or pair of jeans.
Why smart people consider it 'fair' for my neighbor to pay next-to-nothing for 'civilization' while I have to pay a substantial chunk of my income, I'll never understand. Same service, same price.
Because you would benefit disproportionately from those same services due to the diminishing marginal utility of income. In real terms, if you don't engage in progressive taxation you are being subsidized by those poorer than yourself and subsidizing those richer than yourself.
Is your belief in 'diminishing marginal utility of income' your real argument?
The diminishing marginal utility of income is an assumption. In most cases it's a valid assumption, but not always.
Let's say I could show you a situation where a certain individual's marginal utility of income increased with income - for a portion of the utility curve, the curve is convex, not concave. Such situations aren't typical, but they do exist - 'diminishing marginal utility' isn't a law of nature, it's just an assumption.
In such a situation, maximizing utility means certain less well-off people (those on the concave portion of the utility curve) should be subsidizing the more well-off people (those on the convex portion of the utility curve).
In other words, if the goal of taxation is simply to increase utility, in those situations the poor should be subsidizing the rich. If I can show you that for me, each additional dollar has increased utility, you should be willing to concede that that the poor should be subsidizing me.
Yet I've never met a person who used the 'diminished marginal utility of income' argument who was willing to concede that. If you are, you'll be the first.
In other words, arguing diminishing marginal utility's usually just a time-wasting distraction. While it sounds good, I suspect it's not the reason for your argument all.
You're describing "tax deductions", i.e. unusual cases where you extenuating circumstances have reduced their overal utility. How does this work against any aspect of my argument above?
>I suspect it's not the reason for your argument all.
You're right. I think non-progressive taxation is unfair, because there is a diminishing marginal utility of income and I believe that fairness and justice are necessary in society.
Anyone putting their time and/or money to work on a risky enterprise where the expected value is negative - which includes most startup founders and angel investors.
What we do for a living doesn't seem rational - typically, we get back far less than what we put in, especially if you consider opportunity costs. But yet we still do it.
Why do we do this? Entrepreneurs don't strike me as irrational - as a group, I'd consider us more rational than average. Instead of dismissing risk-takers as nuts, you should listen to what our behavior is loudly telling you - our utility curve isn't concave, it's convex. Risk-taking behavior in the face of negative odds only makes economic sense if marginal utility of income increases, not decreases, with income.
You know, it's not only entrepreneurs whose actions shout "hey, diminishing marginal utility of income isn't valid." Anyone who buys a lottery ticket does it too. People aren't stupid. Everyone knows they're on average only getting back a fraction of the money they put into a lottery. What their actions actually tell you is "hey, I value the incredibly small chance of getting rich so highly that I'm happily taking what would otherwise be considered a sucker's bet."
If you really want to maximize utility in the tax code, you'd have to have all of those who behave in risk-adverse ways (with concave utility curves) subsidizing all of those who behave in risk-loving way (with convex utility curves). Which goes a fair bit beyond 'tax deductions'.
Honestly, the way people actually behave makes me think diminishing marginal utility of income is completely questionable - instead, many of us believe and behave like there's an increasing marginal utility of income.
But enough about economics - the argument we're having really hinges on the definition of concepts like 'fairness' and 'justice', which is what you should've started with, not some utility curve argument that's only tangentially relevant. No matter what the utility curve looks like, progressive taxation is repugnant because it's neither fair nor just. It clearly violates the principle of equality before the law - even though all men are created equal, progressive taxation makes the property rights of the wealthy less important than the property rights of the poor. If taxes are a necessary evil, and I suspect they are, they should be proportional, not progressive.
>Anyone putting their time and/or money to work on a risky enterprise where the expected value is negative
That's crap. If the expected value is negative, then it's irrational – clearly there is some outcome with a positive ROI. VCs don't act out of the goodness of their heart.
>you'd have to have all of those who behave in risk-adverse ways (with concave utility curves) subsidizing all of those who behave in risk-loving way (with convex utility curves). Which goes a fair bit beyond 'tax deductions'.
Are you familiar with the capital gain tax? It looks like we already do subsidize risk takers.
> the argument we're having really hinges on the definition of concepts like 'fairness' and 'justice' (...) progressive taxation is repugnant because it's neither fair nor just. It clearly violates the principle of equality before the law - even though all men are created equal, progressive taxation makes the property rights of the wealthy less important than the property rights of the poor. If taxes are a necessary evil, and I suspect they are, they should be proportional, not progressive.
This is a red herring. I'm confused as to how we are supposed to discuss economic policy without resorting to using economics.
I am in complete agreement that taxation needs to be proportional. I just think that they should be proportional to real purchasing power, instead of being proportional to income.
>Risk-taking behavior in the face of negative odds only makes economic sense if marginal utility of income increases, not decreases, with income.
You seem to be intent on misrepresenting it the concept of marginal utility. Making more money will always increase your utility; it just does so at a smaller rate.
If you have a yearly income of $20,000 a $1,000 raise is going to make a much more significant difference in your life than if you make $80,000. If it costs a minimum of $10,000 a year to clothe and feed yourself, a 10% flat tax is going to affect someone who is poor a lot more than it is going to affect someone who isn't.
This is what is unfair.
> the way people actually behave makes me think diminishing marginal utility of income is completely questionable
You've yet to present an argument against this idea. Casting it aside because it is ideologically convenient for you does not make it untrue.
The government is protecting 10x as much stuff from the state of nature for you. Also, the job that you have that pays 10x as much wouldn't even exist because there are many more links along the value chain of a high value job than a low value job. The government protects all of those links from theft in many, many ways. Seriously, suck it up -- in Mad Max world, you would be your neighbor's bitch.
This would be a real argument if the government's only function was to protect stuff from the state of nature, if the costs of protecting stuff were linear, and if the only alternative to the current way of doing things was a 'Mad Max world'.
eh, if you live in a different neighborhood, (and you probably do, if you really earn 10x as much) you certainly are getting a vastly different level of police protection.
I mean, sure, that's mostly local money, and it's a small portion of what you are paying in taxes, but people who live in good areas have a vastly different relationship with law enforcement than people who live in bad areas, and really, should be charged quite a lot more for that law enforcement, as they are getting vastly better service.
(granted, law enforcement, and the federal oversight of law enforcement is a small amount of our taxation; but it is the most obvious place where the rich get vastly more out of the system than the poor.)
Do you ever receive packages from UPS? Do buy food from a grocery store?
How do you think those things get paid for? You really think the $2 per pound you pay for tomatoes includes the true cost of growing a tomato and getting it into your car? If so, I've got a bridge you might be interested in...
Please stop promoting this nonsense that our current level of taxation is needed because of infrastructure needs. Transportation accounts for a measly 4% of the federal budget. Most of our tax dollars go towards military and paying for the old people in society, both of which are politically-charged budget items that politicians refuse to address.
Lowering taxes does not stop the military. Spending is one side, taxing is the other. Bills that run up must be paid, or war fought over them. The solution to overspending is to find a way to stop the spending.
Regarding old people, as a group they worked pretty hard to build the modern world and its conveniences and efficiencies that we enjoy, so I don't mind paying them dividends.
Do you use the Internet? GPS? Do you drive on roads? Do you buy goods from companies that utilize those roads and infrastructure? Do you benefit from protection by police and fire departments? Do you live in a building up to a certain safety code? Do you drink water? Do you deposit money in FDIC insured banks? Do you work for or own a company that benefits from any of these things?
That's only a counter argument if it takes 100% (or heck...even the majority) of taxes to pay for those things.
If 96% of our taxes are being spent on things you hate, and have no practical purpose for you.... isn't it right to dislike taxes in general, and question the government as bloated and inefficient?
Of course I've received a package from the bankrupt and insolvent USPS and yes I also buy food from grocery stores that receive food over roads badly in need of repair.
I didn't say that the government does not do or provide ANY good things. However that does not mean that paying taxes to a government that IS inefficient and bloated can or should be called the "common good". The same government spent over a trillion dollars on wars in Iraq and Afghanistan. Are those wars part of the common good? The same government spends half a trillion on welfare of various sorts. Is that welfare part of the common good? The same government got us almost 15 trillion dollars in debt. Is that debt part of the common good?
Different people may say yes to one, two, or all of the three things above. I, however, would say no to all of them. To me, paying taxes to the government is most definitely NOT the common good.
You mean the fuel taxes that everyone pays, which is routinely raided for things like LRT railways virtually no-one uses, and giveaways to Warren Buffett's freight railroad company?
Here in PA they took $40 million from the fuel tax fund and gave it to the railway companies to modify all the underpasses, so they could stack containers 2-high all the way without the top one getting stuck. And that is just one state, and one example.
If anything, fuel taxes and road maintenance are one thing the govt (sort of) gets right, in that it is a tax on usage of something and automatically scales up or down depending on how much you use the resource. If only they would stop stealing from the funds for non-highway purposes...
There are thousand of problems to fix. The infrastructure is going to collapse under the weight of non-maintenance, there are people infected with HIV virus, Africa needs help to develop, strong artificial intelligence might someday start making paperclip out of humans, etc.
Yeah, it's a problem. The problem is we can't all work on every problem. Some of us have jobs, personal crisis, or is already working on one of those problem.
And some of us think democracy is a really stupid idea.
Mostly, I just focus on internal improvement, since it is something that I can change within myself. Trying to take on the local corrupt buffoon of a government thinking you can rule the city better is a definition of hubris.
> The problem is we can't all work on every problem.
Which is exactly the point of a representative democracy. We elect other people to work the problems we can't. If they do an unsatisfactory job, then we should elect someone else.
I don't know enough about this particular tax rule to say something useful but on the general idea of a 'tax holiday' I do have some thoughts.
Ad-hoc government policies are wrong. Tax holidays, cash for clunkers, amnesty for illegal immigrants, tax credits for favored businesses, loan-gurantees for that new stadium or 'preferred' manufacturers (e.g. Solyandra), health care 'waivers' for certain companies, are all examples of ad-hoc government.
These sorts of policies shred the idea of equality under the law, encourage rampant lobbying in order to gain 'legal' favors, enable politicians and bureaucrats to wield power preferentially, reduce the predictability of the legal and financial environment (taxes, fees, licenses, etc), and skew economic decisions to fit into legislative time windows.
Laws should be uniform and consistent rather than moving targets with varying applicability.
I totally agree. Not only does it make the tax code much more complicated than it needs to be, but it also discredits the "fairness" of taxes, damaging the very legitimacy of it.
Given the past experience with the 2004 tax holiday (little economic investment effect), the current proposal should be rejected. And to allow another tax holiday only sets the expectations that additional ones can be lobbyed for in the future, meaning these companies will again hoard foreign profits offshore in hopes of repeating this request again and again and thereby depriving the government of timely tax revenue.
This is a quite blatant attempt by these companies to game the tax system for their own (not public) benefit. As others have stated, these companies obviously held the foreign profits abroad hoping to have/create this type of lower tax opportunity to bring back those profits.
However, I don't blame these corporations for trying this - corporations' jobs are to make and keep as much money as possible, mostly in response to shareholders' desires for greatest economic returns. Anyone who owns stock in Apple and Google is a part of the reason for this attempt. If this tactic works, the market value of Apple and Google will increase and isn't that what essentially all shareholders want? Frankly, if these companies voluntarily paid all taxes without trying to find ways to minimize them, most shareholders will be furious at management.
Government, through its various corporate/tax laws, sets the limitations on what is permissible and not for corporations, and it hopefully tries to do it in the way that maximizes overall public benefit (balance regulation against enough corporate freedom to incentivize economic growth). The problem I see is that special interest groups have disproportionate power through buying influence. In order to prevent recurring instances of this same situations, the government should firmly show that it will not grant tax holidays now or in the future (then maybe companies will bring foreign profits back right away to the US, thereby paying taxes on time and maybe hopefully spurring economic investment).
My Conclusion: Companies (at least public companies) aren't wrong to try to maximize their value in every way within the controlled environment created by governments. The government should act in the way to incentive corporate actions in the best interests of the public (whether it be more tax dollars or economic growth or another objective). Just say no to the tax holiday.
The corporations' managers cross the line from self-interested to sociopatgic when they pass from enjoying current laws to lobbying (bribing) for new laws to suit heir interests.
anyway, this is absolutely unacceptable. those corporations knew what they were doing right from the beginning. they kept their profits overseas and were hoping government will decrease corporate tax at some point. it didn't happen, now they are applying political pressure so they don't have to pay the same tax rate as rest of America. THIS IS BULLSHIT and is not fair to rest of the society. damn you Google, Apple and Cisco
Here's a better idea. Google and Apple take their taxes back to the US AND they pay tax on those profits. That would definitely help the economy and the budget.
It's so sad that corporations can't seem to actually apply ethical judgements in situations like this. Apparently the shareholders are better served by overseas unrepatriated profits than by actually receiving dividends which have had tax paid on them. And having a national government that can fund the infrastructure for their US offices.
(Not a tax laywer so reality may differ from opinion)
I'm not a tax lawyer either, but I did stay at a holiday inn last night... Which sadly is my only qualification to comment on this topic. In any case here is how I see it, not that I'm right.
Shareholders of international companies are better off if the company doesn't pay the tax penalties from repatriation. Those shareholders will pay taxes on dividends and capital gains, if nothing else. But the question is why would a company bring money back from China (for example) only to pay taxes on it before sending it back to China to pay for the next round of manufacturing? Also, international companies almost always are required to pay taxes on the profits in the country it was earned. There are games you can play to show the profit in your home country, but those are unethical. To understand why think about it from the point of view of each country a company operates.
When accounting decisions do come down to questions that could go either way, profit is shown on the books in the country that would incur the least tax expense. Its exactly what most individuals do. For example I love the big city I live near. However, I chose to live outside of city because a don't want to pay for the city government services when the little town I chose live in has similar services and lower tax rates. I pay for the city services I use through the city sales tax, but they are crazy if they think I'll start paying city property taxes on a house that I already pay property taxes on to another town. If I did own both a city home and a home in the smaller town, there is no way I would be OK with the city bring to tax me on both. Similarly Apple pays taxes on its US operations to the US but why should it pay the US taxes on foreign earned profits that it already pays foreign taxes on?
I have a hard time faulting a company for not paying anymore than the rules require. Unless every company can agree on how much extra they should pay above the minimum, a company not minimizing their tax burden is at a financial disadvantage and will lose marketshare and eventually be marginalized. The only way I know that you can obtain an agreement to the amount of taxes that should be paid is by changing the tax law. Want more capital brought back into the US economy? Lower the taxes below those of the countries the US is competing with for that capital. Want US companies to pay more taxes? Raise the base tax rate, and close loop holes. While I'm thinking of it... Loop holes are almost never what we think they are. The vast majority are not some shady accounting trick dreamed up in a darkly lit room by a weaselly accountant or tax lawyer. They are discounts on the tax rate voted on by congress, usually intended to produce some good like creating jobs.
Really though, if you think about it... It only makes sense to make it easy on companies to move money into the US. If a company wants its cash back in the US, there are only three thing I can think of it would do with it. 1. Put it in the banking system, which grows the economy and increases taxes. 2. Spend it, which grows the economy and increases taxes 3. Give it back to investors, who pay taxes on it and then do one of the other two things.
> Though the studies found that money brought home in 2004 ended up benefiting a narrow set of shareholders, support is growing in Congress for the tax holiday as companies expand their roster of lobbyists.
It's really sad how U.S. government policy is now so openly for sale to the highest bidder.
If what was going on in the US took place in another country we'd call it corruption and bribery, yet we're supposed to accept the current rule by lobbyists and campaign donations as acceptable. It seem inevitable that the increasing economic inequality and lack of real democracy will lead to significant unrest.
The title of the article should be "Google, Apple now powerful enough to hold the entire world to ransom". Given the numbers in the article, that's ~$520 billion of tax revenues they're withholding from the state, and ~$1.5 trillion of liquidity they're withdrawing from Ireland or wherever (someone check the numbers?).
The thing going for the US is that it's still a good place to spend that money, otherwise they wouldn't be contemplating repatriation in the first place.
Arguably, if these companies steadfastly hold on and do not repatriate their funds without a tax holiday, their shareholders should punish them for only making imaginary money... not that it'll hurt them in a real way.
If the US were to grant this tax holiday, they should've set a 0% (or 5.25% or whatever) corporate tax rate to begin with. At least it'll be fair to everyone.
How is this idea even on the table considering current deficit budgets. Regular people don't have the luxury of pulling a fast one on the IRS and pay their dues.
Corporations do have to pay taxes on overseas earnings if they want to bring those earnings back to the US. As far as I'm aware, it's the same for US human citizens. (It's certainly the case for Australian citizens.)
No, US citizens have to pay taxes while abroad whether or not they are returning to the US with it. In fact, some US citizens who have never lived in the US bur have citizenship through inheritance are having a hard time understanding why they are being taxed by a country they have never lived in.
You kind of pay the maximum of the US and domestic tax rates, after some possible deduction, though not exactly the case given how it gets calculated. But yes, all income worldwide is taxed for US citizens. If you're curious, see:
You pay after the first $92.5k. you pay the difference between what you would be taxed in the US minus what you are taxed in your current country. This only becomes a problem if you are living in a country with no or low taxes; ie, HK, Dubai, Saudi Arabia, the Caymans, etc. If you live in Western Europe you are being taxed higher than in the US.
Switzerland is a difficult subject because they don't identify you when they report your taxes so the IRS has to trust the Swiss gov't is telling the truth. I believe they have reached an agreement that favors the US and have a lot of Swiss account holders pissed off.
US corporations have wholly owned subsidiaries outside of the US.
Its as if you moved to Ireland, and had Irish children. These children wouldn't have to pay taxes to the US even though they're all supporting the same family.
I am very curious to see what would happen if, instead of a tax holiday, the US Government announces that it would permanently increase the tax from next year. Would that be an alternative way to encourage big corps to bring profit back now?
The sad part is: both Democrats and Republicans are beholden to the corporations, and not to the voters.
Every law that gets passed has these hidden loopholes and exemptions that benefit a select few corporations. Who puts these loopholes in? This is all done surreptitiously, and I've yet to see any accounting for these loopholes.
What we need is a Wiki-like system while drafting legislation, so that every edit can be tracked to the author(s).
I won't rule here on whether corporations are good/bad or if they deserve the profits. I'd just like to posit my analysis of the situation, which is that:
1) It's been well documented in the financial press now that banks and companies are holding more cash than ever. In fact, Apple is holding more on hand than the gov't.
2) This tax break would be a one time infusion. Corporations can't count on it recurring, if say, they wanted to plan on using it to fund operating expenses (e.g. salaries).
3) Historically, older corporations do not hire sizable numbers of workers. To what extent are these the companies with offshore profits?
Ignoring any ethical judgements, to say that it will help boost the economy seems dubious to me.
Again, ignoring ethical judgements, I think it is fun to consider other consequences, like what effect it may have on corporations' investments on foreign soil. We might not be able to make jobs here, but maybe we could nudge them away from making jobs there? It only works if you think the world economy is not interconnected though.
Anyway, my point is that, yes, there are good moral arguments why this push is reprehensible, and people are making interesting points as such here. Going the other way, I'd like to think about what the hardheaded economic realities are (and they certainly are not about direct job creation). What if it merely adds dollars that these corporations could use for other causes, like lobbying? To what extent do we consider these activities to be good or bad? Donations to charity and contributions to PACs are often one-off.
One thing that tickles me is that when donations are big, they go into endowments, which are managed by various financial companies. Good for the charities, but it's not that there are other vested interests. ;-)
This is the exact sort of "tax loophole" that should be put to an end. I almost wish someone pushed back by proposing a raise in taxes for such behavior, and maybe next time these big companies would think twice before they tried to avoid paying taxes that everyone else does.
So, if this is the "carrot" to get corporations to repatriate this wealth, (ignoring business as usual), what would the "stick" look like?
Maybe a small, token increase? Or some method of increasing the tax rate dependant upon the length of time between the date the money was earned versus payed out as dividends? Surely stockholders wouldn't let companies sit on cash (that would eventually come back here anyway) if that were the case.
You wouldn't even have to be successful, just make a boisterous push to ram THAT through Congress. See how quickly these same companies try to get their assets here under the current tax law.
our corporate tax rates as I understand it are second highest in the world. That is offset by the fact that they are riddled with loopholes and deductions.
We really need to eliminate special loopholes and deductions and then reduce corporate rates.
Having a large spread between US and offshore tax rates obviously gives an incentive for US corps to move factories and such overseas, rather than to export from the US. I don't see any reason to have incentives for that behavior.
Reduce all of the paid for deductions and bring rates down. Simplify.
Wouldn't this be a good thing? The money would come back into the US, and if the tax break isn't given then it won't be coming back.
I'm as cynical about corporations as anyone, but in this case.. they use 100% legal means to reduce their tax, behaving exactly how anyone would expect them.
Some argue that it is an ethical issue, but that neglects the fact that these companies make a large proportion of their profits offshore, and bringing that money gets taxed too. Ethics in this argument are much more subtle than some would have you believe.
They use 100% legal means to keep money off shore. True. But then they ask for a Tax Holiday when that arrangement no longer suits them.
One way or another, that money will return to the US, and the tax will be paid accordingly. This will happen over a long period of time. If the US allows this tax holiday to happen, it will be throwing away billions of dollars in the long term with no real short term advantage, whilst sending a very dangerous message to people who use tax avoidance as a long term fiscal strategy.
It's corporate Americas job to make try and make the system work for them. It's the governments job to try and make the system work for everyone.
One way or another, that money will return to the US, and the tax will be paid accordingly.
See, that's where I disagree. All those companies can easily invest that money offshore, either in financial institutions or in building new facilities. Both seem to be worse outcomes for the US than this.
To be clear: I don't believe in the "trickle down effect" - I think a progressive system is the only sensible one. BUT I do think any trickle down is better than nothing.
sending a very dangerous message to people who use tax avoidance as a long term fiscal strategy
It's not tax avoidance, it's tax minimization. There is a big difference.
The message I see at the moment is "shift your profits and investment offshore, because it is cheaper". I'm not convinced that is beneficial.
It's the governments job to try and make the system work for everyone.
>It's not tax avoidance, it's tax minimization. There is a big difference.
I thought "Tax avoidance" was the legal term for legally minimizing your tax burden, so "avoidance" and "minimization" would be largely synonymous. "Tax evasion" I thought, was the term for avoiding taxes through illegal means.
It's a bad thing because it would create dangerous precedence for the future when every rich corporation would start blackmailing US government as to avoid to pay their fair share of tax. this would hurt US economy far more in long-term, you don't want to encourage this practice
Also, who cares about their trillion dollars... who gives guarantees this money will actually end up in national economy and not invested overseas with profits tied up in some off-shore country once again.
if America needs more liquidity in economy, ring FED. they will print just as much.
The idea does have a downside as well. These recurring tax holidays amount to a selective corporation tax cut for large international corporations. Smaller domestic companies do not benefit from it. Wouldn't it be simpler, fairer and more effective to cut the corporation tax rate?
Why do you think they put it overseas in the first place? They've planned to take it back under these terms all along. They're betting on a tax holiday at some point. Exactly what they did in 2004.
Give them this one, and rest assured, every company will take this bet and let the cash sit and rot until they can bring it back again.
Not really. They did the same thing in 2004, and it didn't do much of anything. And if we keep doing this every time big businesses push for it, they're only going to bring money back during predictable tax holidays.
There is going to be a rush to judgement, but I'm not convinced that the government is going to use the tax money wisely. There are too many people in the business of defrauding our government, trillions are wasted on wars, and millions on earmarks. The government knows how to bail out wall street, but they can't turn the economy around.
Out of all big international corporations in the US, I would argue that Google and Apple are the most socially responsible (apart from privacy concerns). It won't make sense to bring it back to USA so it can sit in bank accounts and accumulate interests, because those funds are currently accumulating interest as we speak.
The obvious uses would be for spending, perhaps for acquisition and growth. The money would eventually be taxed. Keeping the Government in the pinch has forced them to crack down on waste and fraud. It would be much harder for them to bail out wall street this time around.
I would argue that Google and Apple are the most socially responsible
Can you present that argument? I understand that Google does what it can design and build environmentally responsible data centers, but what else does it contribute to the public good?
> There is going to be a rush to judgement, but I'm not convinced that the government is going to use the tax money wisely.... Keeping the Government in the pinch has forced them to crack down on waste and fraud. It would be much harder for them to bail out wall street this time around.
Do you really mean to say that the solution to our budget problems is less revenue? The current deficits are the result of simultaneous decreases in revenues and increases in spending (http://www.taxpolicycenter.org/taxfacts/displayafact.cfm?Doc...). To get back to a balanced budget, we need more revenue and (eventually) less spending.
And I don't know to what extent the government has been forced to crack down on "waste and fraud." Certainly, that's not exclusively what's being cut.
The money wouldn't just be taxed eventually, it would also be taxed immediately, though at a reduced 5.25% rate instead of the usual corporate tax rate. And if a corporation repatriating income uses it to pay dividends, or for share buybacks (resulting in capital gains), this will result in taxable income for the shareholders.
US companies in general are sitting on $2Trillion in cash. Productivity is sky high, because of all the lay offs across the economy, and profits are generally up across the board in most sectors of the economy.
US companies aren't spending because they don't want to spend. They aren't hiring because they are productive enough and are profitable enough without hiring. They are also scared because of all the uncertainty in the financial sector, not necessarily because of the high taxes.
The few people that are actually putting money to work in this economy are angel investors and VC's by giving small engineering teams small amounts of cash as well as leeway to experiment at building interesting products.