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Comment Re:U.S. profits too??? (Score 1) 89

The second component is profit moving - the resultant profits can be moved between the resident company and the non-resident company at no (or extremely low) taxes, but moving the money out of the EU to the external HQ would be taxed heavily from Ireland. However, this is not taxed heavily in Holland (due to historical attachments to the Dutch Antilles). So the organization move the money to Holland (inter-EU transfer, low tax), and from that subsidiary to the tax haven (Dutch law, low tax) and then have it in a tax haven for a very low cost. Where they sit on it because the US tax is punishing.

Thank you for the accurate clarification, this is indeed so and I should have explained it in more detail but I was running out of time and had to post an insufficient explanation of the scheme.

The solution is not higher taxes, it's closing these gaps that companies exploit.

You are indeed correct. This case (and other like it) revolve around whether or not the companies can be taxed for using those loopholes (which are now either closed or being closed) in the past. In other words what's being debated is whether or not the national Dutch/Irish laws that have been exploited for this effect were in line with EU laws and agreements,

Comment Re:EU has no tax powers (Score 1) 89

Actually, that's not correct. They're enforcing an agreement that all companies inside a jurisdiction have to be treated the same. If Ireland wanted 0% corporate tax, and applied that to everyone that would be inside the rules. What the Commission decided is that the deal Apple got was an unfair subsidy because no-one else used it. Ireland and Apple say that it was available to everyone, so it wasn't a subsidy and it wasn't unfair.

Comment Re:U.S. profits too??? (Score 1) 89

The double Irish tax maneuver is worthless on its own without the Dutch sandwich.

The double Irish involves having an Irish registered company legally headquartered elsewhere than the EU (like the Caymans) as well as an Irish registered company headquartered in the EU. This used to be allowed, but it is not allowed any more (and existing structures of this sort have to wind down over the next few years).

There are two components to this. First, the Irish tax is based on where the income is made and only tax Irish income, so do not tax based on income from sales outside the country. This seems reasonable on it's own, but it interacts with other countries tax rules which tax based on where the income is booked. As a result, a company can book profits in Ireland, and fall into the gap between these positions.

The second component is profit moving - the resultant profits can be moved between the resident company and the non-resident company at no (or extremely low) taxes, but moving the money out of the EU to the external HQ would be taxed heavily from Ireland. However, this is not taxed heavily in Holland (due to historical attachments to the Dutch Antilles). So the organization move the money to Holland (inter-EU transfer, low tax), and from that subsidiary to the tax haven (Dutch law, low tax) and then have it in a tax haven for a very low cost. Where they sit on it because the US tax is punishing.

The solution is not higher taxes, it's closing these gaps that companies exploit.

Comment Re:U.S. profits too??? (Score 1) 89

The fact that the Irish branch barely employs any people and is largely just a convenient IP holder makes this even more blatant.

Apple Ireland employs around 4,000 people in Cork, in areas from sales to finance to customer support. It's a major employer in the city and has been for over 30 years, where it used to provide a lot of manufacturing jobs (few of these are left now). The only country in the EU with more Apple employees is the UK, where the number of Apple retail stores (37) explains the difference.

So it's hardly a brass-plate operation.

Comment Re:U.S. profits too??? (Score 2) 89

Apple doesn't transfer U.S. profits to to the EU, so how is it fair for the E.U. to tax Apple on U.S. profits again exactly?

To my understanding this is not about US profits. The 14 billion comes from Apple applying what's known as the double Irish tax loophole that used to exist in Irish law, allowing them to effectively dodge paying taxes to either the EU or the US. Quoting the wiki:

two Irish companies are used in the arrangement. One of these companies is tax resident in a tax haven, such as the Cayman Islands or Bermuda. Irish tax law currently [NOTE: not anymore, wiki wording is out of date] provides that a company is tax resident where its central management and control is located, not where it is incorporated, so that it is possible for the first Irish company not to be tax resident in Ireland. This company is the offshore entity which owns the valuable non US rights that are then licensed to a second Irish company (and this one is tax resident in Ireland) in return for substantial royalties or other fees. The second Irish company receives income from the use of the asset in countries outside the United States, but its taxable profits are low because the royalties or fees paid to the first Irish company are tax-deductible expenses. The remaining profits are taxed at the Irish rate of 12.5%.

For companies whose ultimate ownership is located in the United States, the payments between the two related Irish companies might be non-tax-deferrable and subject to current taxation as Subpart F income under the Internal Revenue Service's controlled foreign corporation regulations if the structure is not set up properly. This is avoided by organizing the second Irish company as a fully owned subsidiary of the first Irish company resident in the tax haven, and then making an entity classification election for the second Irish company to be disregarded as a separate entity from its owner, the first Irish company. The payments between the two Irish companies are then ignored for American tax purposes.

The loophole was closed last year:

Under Finance Act 2015, a new system has been introduced whereby innovative companies who choose to incorporate in Ireland can now benefit from the introduction of the Knowledge Development Box (the “KDB”) in Ireland, the scheme is seen as a replacement for the “double-Irish” tax system which was recently closed. An effective tax rate of 6.25% can be obtained on qualifying profits generated in periods commencing on or after 1 January 2016.

So Apple (and other large tech companies) have been using both the double irish as well as its other variant the Dutch Sandwhich which functions similarly, to dodge taxes on both sides of the Atlantic, while claiming to European tax-authorities that they're paying tax to the US, and to the US that they're being taxed in Europe, while in reality the majority of the income is not taxed in either. The EC is arguing that the use of these loopholes goes against EU regulations and that they now want these companies to pay what they actually should have been paying all the time. This is going to drag in courts for a long time, and Apple is going to claim that since it functioned within Irish law (at the time) it shouldn't have to pay anything. The EC on the other hand, is going to build their case on the grounds that the Irish law itself that allowed for this arrangement was in breach of EU law and cannot be followed and back-taxes are owned.

This whole case is one of several ongoing ones regarding the use of tax-havens to dodge corporate taxes, which has been (and still is in some senses) relatively easy to do for large multinationals. The EU is currently trying to crack down on it, whereas the US, especially now under Trump's heavily wall street backed cabinet, is going to be unlikely to do much and is probably going to take the side of american companies, despite the fact that by doing this they're essentially aiding - and encouraging - American companies in to engage in tax-evasion, which is in the end also hurting US tax-revenue.

Comment Solve for fair taxes (Score 1) 89

This issue is very simple to solve with a few changes to tax policy.

1. Remove deductions for Intellectual Property payments. This is the chief way corporations avoid tax. Example, Burger King / Tim Horton merger.

2. Profit, no matter where situated, is taxable in the country of origin. Example: If Apple sells 100 billion in the US, then the gross profit of that 100 billion is due in the US. Self dealing exchange of expenses by off shoring 99.9% of the price of the phone (or other product/service) would no longer be allowed.

These steps will never be taken because they would be incredibly disruptive in the first place, and in the second place, there is no will in Washington to make corporations or billionaires actually pay taxes as the average person does.

Comment Re:But this isn't sexism. (Score 1) 740

Woosh.

They bought jackets for all the male staff, but didn't for the females. That's blatent discimination and sexism from a company. Who gives a fuck what it costs? Buy them the fucking jackets, they earnt them as much as the boys.

She explicitly said they had the option to get a "male" jacket. I don't know off the top of my head what makes a leather jacket feminine vs. masculine, but I've seen a woman wearing a leather jacket from the men's section and, as long as the size is right, it looks fine. Feminine versions of clothing generally consists of being tighter or having frivolous trim or something. There's no functional reason to have a separate female version of a leather jacket except to pander to gender stereotypes. Which is itself supportive of a mild form of sexism, not a remedy for sexism. I mean granted, you can make an argument that they should get all female jackets and the men should have to adjust to those, except as I just pointed out male clothing tends towards the more utilitarian[1].

if it makes the employee's work place a nicer place to come to

That has nothing to do with anything. The issue is whether or not it is sexist to not specifically cater to a separate, stereotypical feminine aesthetic. One that's not shared by all females, for that matter. If the women showed up for their first day at work and their computers had the aforementioned hot pink with glittery flowers (without them asking for it) and their male counterparts had normal looking computers, I bet she'd be crying sexism. But it's the same thing in principle. Equality means equality, not asking for special treatment because you're been sociologically conditioned to hate leather jackets if they don't have a fringe or the buttons on the left side or come in pastel colors or whatever the hell it is that's supposed to make a leather jacket feminine.


1. Well, at least as far as jackets go. Women have a clothing advantage in most warmer contexts.

Comment But this isn't sexism. (Score 1) 740

A boss making a pass at an subordinate is not sexism. It's a big problem, yes, and it doesn't sound like Uber handled it very well if the woman's account is accurate, but there wasn't any trace of sexism throughout the entire story that I saw (I was skimming) except for the meeting with the HR woman she briefly described at the very end.

The bulk of her story seemed to be just vague conspiratorial stuff, implying her poor performance reviews under another manager on under team was due to the original boss's evil influence which... I don't know, anything's possible, but it doesn't seem like a reasonable default assumption. In the crazed and cutthroat culture she describes, it seems more reasonable to assume it was normal bullshit, not evil anti-woman bullshit.

Oh yeah, and she seemed to think that the company's refusal to order a special feminine version of the special leather jackets they had bought constitutes sexism. Just let that sink in a moment--*not* pandering to arbitrary social conventions that insist a female's jacket has to have a slightly different cut and styling is sexism. Why stop there? Why not insist it's sexism to not give all of the women hot pink keyboard, perhaps spangled with little glittery flowers?

The first step to getting people to take sexism seriously: don't conflate normal (if inappropriate) sexual advances as sexism. That's fucking stupid, and a lot of people will instantly tune you out after they realize that's what you're implying. It's only sexism if there's discrimination involved and, unfortunately for this woman, she's not describing any documented discrimination that I can see. I don't know what I'd tell her except to look up California laws on hidden audio recording, maybe. The HR woman at the very end sounded like she was saying sexist shit, but everyone else, by her own admission, had excuses for her performance evaluations.

Were they bullshit excuses? I'm sure they were. But that's par for the course for performance evaluations in a cutthroat environment; you can't just assume that it's sexism, just because a *former manager on a different team* once made a pass at you.

Comment Re:Professional attention whore strikes again (Score 1) 908

I think the Producers seems to have done rather well.

My broader point was that mainstream tastes and anointment by Hollywood elites was being used to unfairly elevate mediocre works while the same people are only too happy to tarnish a work by a solo creator that is obviously more thoughtful and less sensationalist than the all-singing, all-dancing Nazis with hippy Hitler. Quoting mainstream accolades rather proves my point. Hollywood thought that the tediously formulaic "Crash" was a brilliant movie, too.

If you removed the admittedly hilarious, but also relatively short sequences showing the play-within-the-movie and the audience's reaction to it, the rest of The Producers--the conspiracy leading up to the play and the climax of the story afterwards with the scriptwriter getting pissed--was pretty mediocre. Certainly, it was nowhere near as good as Young Frankenstein.

It is a difficult subject.

The Great Dictator was a much more difficult and (taken as a whole) a better work than The Producers. And it was released just a year after the invasion of Poland.

Comment Operating System (Score 2) 201

The definition of an OS is that it controls all resources of a computer and shares them between the applications.

That is at best a description of some operating systems.

Some operating systems control some computer resources. Some share the resources that they control.

To quote Hamlet:

There are more things in heaven and earth, Horatio,
Than are dreamt of in your philosophy

Comment Re:Reckless endangerment (Score 1) 184

Had someone actually died, it would match the definition of "depraved-heart murder", which is second-degree homicide in many states. Depraved-heart murder is killing someone through actions not actually *intended* to kill them, but by reckless disregard for their safety.

One really messed up part of our judicial system is that punishment is often more interested in the results of the perpetrator's actions instead of the intent. There is no sane reason why attempted murder and murder have different punishments, since the intent was the same. Similarly, there should be no difference in the punishment for depraved-heart murder and reckless endangerment.

Comment Re:Professional attention whore strikes again (Score 1) 908

They can watch the videos for the themselves, you know.

Have you *ever* worked a white collar job in your life, let alone interacted with HR or PR? You are overestimating competence whilst simultaneously underestimating paranoia.

The contents of the videos are strictly secondary to the fact that the Wall Street Journal, the largest newspaper in America (and also the one with the strongest ties to big business), made it clear to Disney that they were going to write a series of articles on PDP's alleged antisemitism. This would be enough to rattle anyone, but Disney has long attempted to quell rumors about its (and Walt's) antisemitism, so they were almost certainly going to avoid the smoke regardless of whether or not there was any fire.

I've heard someone mention the WSJ has posted a compilation of the nine videos they sent (and have admitted to sending) Disney. No idea if that's true; go look for yourself if you want. I am being pragmatic with my time here; I will wait for the WSJ to circle the troops and put out a more robust response and for more enthusiastic people to put together comprehensive lists of links to the relevant videos and articles and relevant quotes with verifications so we don't have to deal with paywalls.

The WSJ hasn't denied it that I've seen. I have no reason to doubt it. If you doubt it, so be it. But I'm not your Google monkey.

one is a comedy where two awful people are trying to be offensive by making a musical about Hitler

No, that's incorrect. The plot of the movie is they are trying to make a play that will be a box office flop.

"Surely, Mel Brooks could have chosen a more socially responsible but still hilariously bad subject for his fictional producers to make a play about!"

the other is a jackass who thinks it's edgy to pay poor people 5 dollars to do something politically incorrect

So just to clarify, you think it's OK to pay privileged white Americans thousands of dollars to do something politically incorrect, but not give $5 to some Indians.

Don't give me that "they didn't know what they were saying" bullshit; those guys spoke English (or at least someone on their end did) and World War 2 and Israel are both pretty well known in India (news/history of the latter is of interest to them because the Hindus are dealing with jihadi problems) so I'm pretty sure they knew what Jews are, it's just that the taboos are very different there. Which actually makes the video all the more interesting and meaningful, albeit not necessarily something PDP was thinking when he made it.

One is comedic genius, the other is tasteless attention whoring.

This is the crux of the matter right here. Limousine liberalism; pure, unadulterated, self-absorbed elitism. It's ok if Hollywood does it, but if it's a simple one-man operation without the glitter, it's held to an entirely different standard. Polish dictates acceptability. I hate it when it's wall street criminals getting away with no jail time for the same crimes that would send an individual away for decades, and I hate it just as much when the example set by the rich is set as the untouchable center of the cultural compass. Which is what you *are* doing, whether you realize it or not.

The Producers, incidentally, was (as I recall; it's been a while) a fairly shitty, unfunny movie apart from the play-within-the-movie with hippy Hitler and the spinning swastika the immediate reaction to it. All of that stuff with the scriptwriter getting pissed afterwards was meh, as I recall. Mel Brooks has done a lot of legendarily good stuff, but consistency or pacing have never been his strong suits.

PDP's Death to All Jews, on the other hand, was a solid piece, with nice contrast between his normal persona leading to an ending that felt very much like something out of a Louis CK's show. I'm sorry if your brain has been so spoilt by American sitcom and dramedy trash to not be able to find any meaning in thirty seconds of stunned silence (real or "faked"--it doesn't matter. Louie's show is no less "faked") followed with a wistful, sad smile.

It showed a finesse and self-reflection that I found much more interesting than the videos I'd seen him in a year or two back.

I don't know why you're obsessed with winners and losers.

I'm pretty sure you're the one who's fixated on PewDiePie being caught, possibly like Scooby Doo criminal. I merely pointed out that the 'catching' and the victory is unfolding in the other direction, though it will take some time for the evening news-addled members of the public to properly process it.

And as an aside, this is another vastly overrated bit of "comedy". There is not enough marijuana in the world to make Scooby Doo funny. Mainstream culture though, that means it must be good, right?

I'm just pointing out that PewDiePie is upset

Regardless of whether or not he was upset a few days ago (or just faking it), he most certainly is not upset now. Again with the out of touch elitism--just how old are you, anyway? You seem to think that just because a shit ton of mainstream media sources are unthinkingly parroting the WSJ line, that means PewDiePie is hurt or worried or something. Whatever he's up to, I'm quite certain he's having a fantastic weekend. He finessed it perfectly, and at this point the battle is already won even if he doesn't mention it again.

It's a mistake to think this is merely his fanboys vs. the world. Four days ago I would have shrugged and said "Eh, whatever. I guess he's ok, but he's no jacksepticeye. And I don't even watch him very much; I stopped being super interested in gaming years before these guys showed up." But now...

Comment Re: Not about the free market (Score 1) 908

I believe my nose and hair look sufficiently Native American, though I don't have the eyes or the skin. If you want to pay for a genome sequencing, I'd be happy to provide you with something more concrete. But more to the point, I grew up in the lower middle class as a fairly direct result of my ancestors growing up in the lower classes, ultimately stemming at least in part from some of my great-grandparents and great-great-grandparents experiencing racism and the associated reduction in economic opportunities.

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