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Corporate Tax Evasion: The Double Irish

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Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Thu Mar 17, 2011 3:31 pm

Just in time for St. Patrick's day, NPR is doing a piece on the Double Irish tax dodge. It's fascinating.


Tyler Hurst swiped his debit card at a Walgreens pharmacy in central Phoenix and kicked off an international odyssey of corporate tax avoidance.

Hurst went home with an amber bottle of Lexapro, the world’s third-best selling antidepressant. The profits from his $99 purchase began a 9,400-mile journey that would lead across the Atlantic Ocean and more than halfway back again, to a grassy industrial park in Dublin, a glass skyscraper in Amsterdam and a law office in Bermuda surrounded by palm trees.

While Forest Laboratories Inc., the medicine’s maker, sells Lexapro only in the U.S., the voyage ensures most of its profits aren’t taxed there -- and they face little tax anywhere else. Forest cut its U.S. tax bill by more than a third last year with a technique known as transfer pricing, a method that carves an estimated $60 billion a year from the U.S. Treasury as it combines tax planning and alchemy.



Among the US luminaries using this strategy are Google, MSFT, Oracle, and Pfizer.

“If multinationals cannot be prevented from shifting profits to low-tax jurisdictions, then it becomes impossible to maintain the domestic corporate tax base,” said Reuven S. Avi- Yonah, director of the international tax program at the University of Michigan Law School in Ann Arbor. If that bleeding can’t be stanched, “we might as well abandon the income tax.”



The interview (I beleive it's Hurst) also notes that in theory, when the funds are repatriated, the government gets their cut. In reality it doesn't. Except when we do something like the 2004 American Jobs Creation Act that granted amnesty and a 5% tax rate (instead of the 35% rate). It enabled companies to bring back three hundred billion dollars at a laughable tax rate. They didn't create jobs so much as they bought back their own stock. In 2005, HP brought back $15B under this act even as it laid off 14,000 workers.
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Re: Corporate Tax Evasion: The Double Irish

Postby Zarathud » Fri Mar 18, 2011 11:06 pm

These structures have been around for more than two decades to help US corporations isolate their non-US income. The IRS changed the rules trying to stomp all over "transfer pricing" techniques, but international corporations got better at tax restructuring and justifying the economics behind it. Then they co-opted Ireland into have an ineffective tax structure with the lure of becoming a Celtic Tiger as the Delaware of the EU.

The solution isn't giving up on the U.S. income tax, but in finding ways to make the rules apply without the loopholes. Subpart F of the tax code has lots of traps to catch this income anyway, but there are still holes that allow the structure to work. Those rules are so technical they make my head ache, but Congress has no incentive to understand the issues enough to fix them.
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Re: Corporate Tax Evasion: The Double Irish

Postby stessier » Fri Mar 25, 2011 3:42 pm

GE is apparently the king!

The company reported worldwide profits of $14.2 billion, and said $5.1 billion of the total came from its operations in the United States.

Its American tax bill? None. In fact, G.E. claimed a tax benefit of $3.2 billion.

******

Its extraordinary success is based on an aggressive strategy that mixes fierce lobbying for tax breaks and innovative accounting that enables it to concentrate its profits offshore. G.E.’s giant tax department, led by a bow-tied former Treasury official named John Samuels, is often referred to as the world’s best tax law firm. Indeed, the company’s slogan “Imagination at Work” fits this department well. The team includes former officials not just from the Treasury, but also from the I.R.S. and virtually all the tax-writing committees in Congress.
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Re: Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Fri Mar 25, 2011 5:25 pm

I'm going to tell my guy to get pretty damned creative this year.

If I am forced to spend time in Dublin to make it legal, then so be it!
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Re: Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Tue Mar 29, 2011 9:45 am

60 Minutes had a similar story on Sunday. It focused on Zug in Switzerland and Transocean and Weatherford. Same stuff though.
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Re: Corporate Tax Evasion: The Double Irish

Postby Zarathud » Thu Mar 31, 2011 12:04 am

Transfer pricing can permit multinational companies to negotiate their tax bills -- at 50% discounts. Multinational corporations have real money at stake in transfer pricing:
U.K.-based AstraZeneca plc announced that it will pay the Internal Revenue Service $1.1 billion to settle all transfer pricing issues for 2000-10, according to a March 28 statement released by the company.

AstraZeneca also noted that the company settled with IRS on the related valuation matter of a 2000 restructuring that followed the 1999 merger of Astra AB and Zeneca Group plc.

In addition to the IRS settlement, the company said that the U.S. and U.K. competent authorities have agreed to bilateral advance pricing agreements covering 2002-14.

As a result of the settlement, AstraZeneca said the company will release amounts from its provision, creating an earnings benefit of $500 million and reducing the company's $2.3 billion net accrual for transfer pricing and other international tax matters. AstraZeneca said that as a result of the provision release, the group's effective tax rate for 2011 dropped from 27 percent to 20 percent.

The global pharmaceutical firm in 2010 reported a $780 million transfer pricing settlement with H.M. Revenue and Customs for 1996-2010.
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Re: Corporate Tax Evasion: The Double Irish

Postby gbasden » Thu Mar 31, 2011 12:12 am

I honestly don't understand how the Republicans can continue to argue with a straight face that we impose a crushing tax burden on businesses. The Daily Show was brilliant as usual about this on Monday.
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Re: Corporate Tax Evasion: The Double Irish

Postby stessier » Thu Mar 31, 2011 6:21 am

gbasden wrote:I honestly don't understand how the Republicans can continue to argue with a straight face that we impose a crushing tax burden on businesses. The Daily Show was brilliant as usual about this on Monday.


The theory is that if the taxes were low enough, no one would bother with all the creative accounting and just pay the piper here. And if all the loopholes were closed and they had to actually pay the taxes due now, they couldn't be competitive.
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Re: Corporate Tax Evasion: The Double Irish

Postby El Guapo » Thu Mar 31, 2011 3:58 pm

stessier wrote:
gbasden wrote:I honestly don't understand how the Republicans can continue to argue with a straight face that we impose a crushing tax burden on businesses. The Daily Show was brilliant as usual about this on Monday.


The theory is that if the taxes were low enough, no one would bother with all the creative accounting and just pay the piper here. And if all the loopholes were closed and they had to actually pay the taxes due now, they couldn't be competitive.


The first part strikes me as implausible. Basically, if corporations (or individuals, for that matter) have a realistic choice between paying more money and less money, then they're going to choose less money. There isn't any rate low enough that they'd choose to pay more when their attorneys and accountants tell them that they can justify paying less or nothing.
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Re: Corporate Tax Evasion: The Double Irish

Postby noxiousdog » Thu Mar 31, 2011 4:35 pm

El Guapo wrote:
stessier wrote:
gbasden wrote:I honestly don't understand how the Republicans can continue to argue with a straight face that we impose a crushing tax burden on businesses. The Daily Show was brilliant as usual about this on Monday.


The theory is that if the taxes were low enough, no one would bother with all the creative accounting and just pay the piper here. And if all the loopholes were closed and they had to actually pay the taxes due now, they couldn't be competitive.


The first part strikes me as implausible. Basically, if corporations (or individuals, for that matter) have a realistic choice between paying more money and less money, then they're going to choose less money. There isn't any rate low enough that they'd choose to pay more when their attorneys and accountants tell them that they can justify paying less or nothing.



Agreed. Most big corps chase every percentage point they can.
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Re: Corporate Tax Evasion: The Double Irish

Postby AWS260 » Thu Mar 31, 2011 5:41 pm

noxiousdog wrote:
El Guapo wrote:
stessier wrote:
gbasden wrote:I honestly don't understand how the Republicans can continue to argue with a straight face that we impose a crushing tax burden on businesses. The Daily Show was brilliant as usual about this on Monday.

The theory is that if the taxes were low enough, no one would bother with all the creative accounting and just pay the piper here. And if all the loopholes were closed and they had to actually pay the taxes due now, they couldn't be competitive.

The first part strikes me as implausible. Basically, if corporations (or individuals, for that matter) have a realistic choice between paying more money and less money, then they're going to choose less money. There isn't any rate low enough that they'd choose to pay more when their attorneys and accountants tell them that they can justify paying less or nothing.

Agreed. Most big corps chase every percentage point they can.

If only someone were to propose closing the loopholes and lowering the tax rate...
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Re: Corporate Tax Evasion: The Double Irish

Postby stessier » Thu Mar 31, 2011 7:41 pm

El Guapo wrote:
stessier wrote:
gbasden wrote:I honestly don't understand how the Republicans can continue to argue with a straight face that we impose a crushing tax burden on businesses. The Daily Show was brilliant as usual about this on Monday.


The theory is that if the taxes were low enough, no one would bother with all the creative accounting and just pay the piper here. And if all the loopholes were closed and they had to actually pay the taxes due now, they couldn't be competitive.


The first part strikes me as implausible. Basically, if corporations (or individuals, for that matter) have a realistic choice between paying more money and less money, then they're going to choose less money. There isn't any rate low enough that they'd choose to pay more when their attorneys and accountants tell them that they can justify paying less or nothing.


The first part only says "low enough." I never said "low enough" != lower than the foreign rate they are currently getting. :)
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Re: Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Tue Apr 30, 2013 12:24 pm

Apple is an interesting example of the real-world effects of the off-shore tax dodge.

They recently announced that they will be doing a return to shareholders through a stock buyback and dividend. The total amount announced was $100B (about half buyback, half dividends). The reasons are many but mostly it's the ratio of cash to growth that will impair ROE and ROA calculations. That and vocal shareholders calling fo something to be done with the cash.

They have around $140B in cash reserves. Seems simple enough, they buy stock with cash and return some of more their reserves as increses in dividents, right? Nope.

They will take on around $20B debt to pay for the return to shareholders. Short version is that the interest on debt will be less than the taxes they'd have to pay to repatriate the cash they have off-shore (and haven't paid US taxes on). Even with the buybacks and increased dividends subtracting from the bottom line (at around $8B/quarter total depending on share price), they will still net $3B/quarter in cash (assuming current growth rates).

Anyway, not saying it's good or bad, it's just an interesting effect.
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Re: Corporate Tax Evasion: The Double Irish

Postby Pyperkub » Tue Apr 30, 2013 3:06 pm

LawBeefaroni wrote:Apple is an interesting example of the real-world effects of the off-shore tax dodge.

They recently announced that they will be doing a return to shareholders through a stock buyback and dividend. The total amount announced was $100B (about half buyback, half dividends). The reasons are many but mostly it's the ratio of cash to growth that will impair ROE and ROA calculations. That and vocal shareholders calling fo something to be done with the cash.

They have around $140B in cash reserves. Seems simple enough, they buy stock with cash and return some of more their reserves as increses in dividents, right? Nope.

They will take on around $20B debt to pay for the return to shareholders. Short version is that the interest on debt will be less than the taxes they'd have to pay to repatriate the cash they have off-shore (and haven't paid US taxes on). Even with the buybacks and increased dividends subtracting from the bottom line (at around $8B/quarter total depending on share price), they will still net $3B/quarter in cash (assuming current growth rates).

Anyway, not saying it's good or bad, it's just an interesting effect.


So, effectively the shareholders will pay taxes at capital gains rates while the corporate taxes are minimized, if I have this tight.

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Re: Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Tue Apr 30, 2013 3:15 pm

Pyperkub wrote:
So, effectively the shareholders will pay taxes at capital gains rates while the corporate taxes are minimized, if I have this tight.

tapatalkin'

Yeah, shareholders will pay dividend rates (same as LT cap gains? Can't remember anymore) for the dividends and pretty much nothing for the buyback except interest on the bonds that partially fund them. Buybacks lower the amount of shares thereby increasing the value of remaining shares, in theory. Most of the $147B cash remains untaxed (here).

Now there will still be additional tax revenue for Uncle Sam as a bit more of the current cash flow will go to dividends which are double taxed.
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Re: Corporate Tax Evasion: The Double Irish

Postby AWS260 » Tue May 21, 2013 9:26 am

The double-double Irish:
The New York Times wrote: Because the United States bases residency on where companies are incorporated, while Ireland focuses on where they are managed and controlled, Apple Operations International was able to fall neatly between the cracks of the two countries’ jurisdictions.

Apple Operations International has not filed a tax return in Ireland, the United States or any other country over the last five years. It had income of $30 billion between 2009 and 2012.

Some insightful analysis from that article:
“There is a technical term economists like to use for behavior like this,” said Edward Kleinbard, a law professor at the University of Southern California in Los Angeles and a former staff director at the Congressional Joint Committee on Taxation. “Unbelievable chutzpah.”
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Re: Corporate Tax Evasion: The Double Irish

Postby noxiousdog » Tue May 21, 2013 10:16 am

AWS260 wrote:Some insightful analysis from that article:
“There is a technical term economists like to use for behavior like this,” said Edward Kleinbard, a law professor at the University of Southern California in Los Angeles and a former staff director at the Congressional Joint Committee on Taxation. “Unbelievable chutzpah.”


That's silly.

I'd be shocked if he wasn't taking advantage of every tax reducing law he could as well.

Regardless, that's why we should have consumption taxes rather than income taxes.
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Re: Corporate Tax Evasion: The Double Irish

Postby RLMullen » Tue May 21, 2013 11:59 am

noxiousdog wrote:Regardless, that's why we should have consumption taxes rather than income taxes.


I agree with you as long as financial instruments are considered "consumables" in this new tax system. :D
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Re: Corporate Tax Evasion: The Double Irish

Postby noxiousdog » Tue May 21, 2013 12:02 pm

RLMullen wrote:
noxiousdog wrote:Regardless, that's why we should have consumption taxes rather than income taxes.


I agree with you as long as financial instruments are considered "consumables" in this new tax system. :D


I don't know what that means. Are you suggesting that if you want to take out a home equity loan you should pay the government 20% of the loan value?
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Re: Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Tue May 21, 2013 12:04 pm

noxiousdog wrote:
RLMullen wrote:
noxiousdog wrote:Regardless, that's why we should have consumption taxes rather than income taxes.


I agree with you as long as financial instruments are considered "consumables" in this new tax system. :D


I don't know what that means. Are you suggesting that if you want to take out a home equity loan you should pay the government 20% of the loan value?

I think he means things like equities.
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Re: Corporate Tax Evasion: The Double Irish

Postby RLMullen » Tue May 21, 2013 12:21 pm

LawBeefaroni wrote:
noxiousdog wrote:
RLMullen wrote:
noxiousdog wrote:Regardless, that's why we should have consumption taxes rather than income taxes.


I agree with you as long as financial instruments are considered "consumables" in this new tax system. :D


I don't know what that means. Are you suggesting that if you want to take out a home equity loan you should pay the government 20% of the loan value?

I think he means things like equities.


Basically a transaction tax on securities and investments. I'm not talking about 20%, but something in the "faction of a percent" range.
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Re: Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Tue May 21, 2013 12:27 pm

RLMullen wrote:Basically a transaction tax on securities and investments. I'm not talking about 20%, but something in the "faction of a percent" range.

Yeah, that's what I figured. I'm not sure doing away with an income tax would necessarily do away with a capital gains tax. Maybe, maybe not.
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Re: Corporate Tax Evasion: The Double Irish

Postby stessier » Tue May 21, 2013 12:27 pm

RLMullen wrote:
LawBeefaroni wrote:
noxiousdog wrote:
RLMullen wrote:
noxiousdog wrote:Regardless, that's why we should have consumption taxes rather than income taxes.


I agree with you as long as financial instruments are considered "consumables" in this new tax system. :D


I don't know what that means. Are you suggesting that if you want to take out a home equity loan you should pay the government 20% of the loan value?

I think he means things like equities.


Basically a transaction tax on securities and investments. I'm not talking about 20%, but something in the "faction of a percent" range.

So you have to pay a tax even when you lose money? Why?
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Re: Corporate Tax Evasion: The Double Irish

Postby noxiousdog » Tue May 21, 2013 12:33 pm

stessier wrote:So you have to pay a tax even when you lose money? Why?


IMO, it's not a terrible idea. A fraction of a percent in an investment is a rounding error. A fraction of a percent in program trading is significant. I'm pretty convinced program trading should be penalized.

Also, if you buy a car it's taxed. Why not when you buy a company?
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Re: Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Tue May 21, 2013 12:59 pm

noxiousdog wrote:
stessier wrote:So you have to pay a tax even when you lose money? Why?


IMO, it's not a terrible idea. A fraction of a percent in an investment is a rounding error. A fraction of a percent in program trading is significant. I'm pretty convinced program trading should be penalized.

Also, if you buy a car it's taxed. Why not when you buy a company?

Good idea or no, you're talking about the strongest lobbying groups out there. Banks and "big corporations." Never going to happen unless they are exempt.

Also, nearly every trade has a fee, either a brokerage fee for retail or an exchange fee for the institutions. A quick look at what happens with exchanges raise/lower their fraction-of-a-percent fees might be a good study in what would happen with a similar tax.
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Re: Corporate Tax Evasion: The Double Irish

Postby noxiousdog » Tue May 21, 2013 2:42 pm

Lawbeef, you'll love this
Goofyhoofy wrote:Actually, if you do the math, the company actually makes money doing it this way.

Bringing the cash home would cost, as we all know, 35% (minus whatever has already been paid.) Taking out a loan at 2% means the cost of the dividends and buybacks will cost 2% more than using the actual cash, which is far less than what tax rate might be available. But wait! The interest on the loans is fully deductible - in this country - so the charge goes against USian profits.

But wait! Even better! Every share that Apple repurchases is a share they don't have to send out a dividend on. If Apple is giving a divvy of $3 a share per quarter, that's $12 a year/share saved, not distributed. How much did the loan coast? Well, figuring 2% on each share repurchased at (say) $450, that's $9 a share. But wait! That's $12 a share forever on every share retired, while the bonds are of varying maturities (3, 10, and 30, IIRC.) so the interest ends, while the savings never does (absent being reissued, obviously.) Apple is spending $9 to save $12 on millions of shares - just the first year. And if they "brought the cash back" to pay the dividend, well, they would be spending the same amount on everybody's dividend, but with a reduced cash hoard to do it.

Does it matter that the "forever" savings is only on the repurchased shares? Not really, since they have to fund the dividend payments for all shares somehow anyway.

No, I am not tax savvy enough to have figured this out by myself, but I remember reading it somewhere a month or two back and thought "clever."

And, of course, the overseas cash remains overseas, untaxed, until a more favorable treatment can be had.

You think the iPhone is well constructed? Apple's use of cash is equally marvelous.
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Re: Corporate Tax Evasion: The Double Irish

Postby LawBeefaroni » Tue May 21, 2013 2:48 pm

Yeah, it's pretty amazing. Nice link.
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Re: Corporate Tax Evasion: The Double Irish

Postby Fireball1244 » Sat May 25, 2013 10:38 am

I'd be in favor of dramatically reducing the tax rate, down to something like 10%, closing all loopholes (except those necessary to provide for financing of *very large* industrial or equipment purchases), and taxing overseas earnings in as un-hostile a way as possible. My notion is to tax foreign earnings at the same rate as domestic earnings *minus* all income taxes paid to foreign entities. This would be a straight on tax reduction, not a reduction in taxable income.

So if company A earned $100 million overseas, their tax bill on that money would be $10 million. However, if they paid $3.5 million in overseas income taxes, their tax to the US government would only be $6.5 million. If their taxes overseas were more than the $10 million tax they owe here, then their tax would be something nominal, like 2%.

I'd eliminate most deductions, but leave in place tax incentives for jobs created in the United States, and establish tax penalties for jobs outsourced from the United States to foreign countries.
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Re: Corporate Tax Evasion: The Double Irish

Postby Zarathud » Sat May 25, 2013 1:52 pm

We already have a credit for foreign tax paid and treaties to harmonize tax systems.
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Re: Corporate Tax Evasion: The Double Irish

Postby Fireball1244 » Sat May 25, 2013 6:34 pm

We credit it in terms of taxable income. We don't directly reduce the amount of tax owed.
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