2013年11月13日星期三
christian louboutin discount value.But what does that mean when it comes to
Business as usual Because apple is so profitable, the dollars involved will
certainly attract attention(This is a senate committee after all, so that is the
point).Corporate income tax by an average of $10 billionayear for the past four
years.Since the corporate levy generated only about $240 billion in 2012, $10
billion foregone from one company is a very big number indeed. But while it
added a few interesting twists, apple cut its taxes with the same tools
multinationals have been using for years to minimize their worldwide tax
liability.And if there is a scandal, i suppose it is the very ordinariness of
these transactions.Apple's tax avoidance shop, it seems, is a lot less
innovative than its phone designers. The tactics are complicated but the
strategy is simple:A company designs its business to locate as much income as
possible in those countries where taxes are low.But only onethird as much in
ireland, where the corporate rate is only 12.5 percent. To achieve these twin
goals, apple mostly relied on the three golden goodies of internationalTax
avoidance:Deferral, transfer pricing, and checkthebox.Tax on foreign income
until earnings are brought back home.Tax.Transfer pricing and checkthebox make
the system even more beneficial. Transfer pricing is the way firms use internal
bookkeeping to allocate expenses among various affiliates.For a company like
apple, nearly all the value of its products is in its patents and other
intellectual property. Firms are supposed to price these assets at market christian louboutin discount value.But
what does that mean when it comes to, say, proprietary computer code?
Checkthebox has been around for 15 years.Originally aimed at simplifying filing,
these treasury rules allow firms to classify themselves as one of several
different entitiescorporations, partnerships and the like.Income tax. Normally,
firms might be subject to rules(Called subpart f)Meant to prevent abuse of
deferral.But multinationals avoid these strictures by designating foreign
corporations they control as disregarded for tax purposes.All they have christian
louboutin ankle boots to do is, you got it, check a box. There is some cost
to deferral.Investments even though it has $100 billion stashed overseas.But if
the benefits didn't outweigh the cost, companies wouldn't keep holding all that
money offshore. How did apple do it?It set up two entities in ireland through
which it was able to funnel twothirds of its pretax worldwide income.Of its $34
billion in total 2011 pretax income, $22 christian louboutin ankle boots
billion was allocated to these two firms.True, the irish love to talk.But it is
unlikely they bought enough phones to generate $22 billion in pretax income.
Remarkably, while these firms were physically located in ireland, they were not
irish companies for irish tax purposes.Thus, they produced what harvard
university tax professor steve shay describes as"Ocean income. "That is, revenue
that simply disappears into the deep blue. Just imagine cheap christian louboutin uk if apple
could replace all those tax lawyers with creative new software geeks or
industrial designers.It might win back some of the market share it has been
losing to android in recent years.
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