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Tax havens could be on the way out - 9/9/2016 2:28:51 PM   
MrRodgers


Posts: 10542
Joined: 7/30/2005
Status: offline
Highlites or...lowlites:

.....the European Commission ordered Ireland to collect more than $14 billion in back taxes from the company. (Apple) The global giant had been attributing billions of dollars in profits to a phantom head office, allowing it to pay a tax rate of 1 percent or lower.

Both Apple and Ireland are appealing the decision, but the commission’s announcement was the latest sign that multinational corporations are running out of places to hide from paying taxes. The door is now open for Congress to fix our own corporate tax code, which has allowed the biggest multinationals to shirk their obligations for decades.

The European Commission is investigating Luxembourg’s tax arrangements for Amazon and McDonald’s, and last year the European Court of Justice struck down tax advantages to companies and their subsidiaries selling e-books throughout Europe. Also last year, Britain enacted a new tax to target profits siphoned off by international companies, nicknamed, without much subtlety, the “Google tax.”

The Organization for Economic Cooperation and Development and the Group of 20 nations are coordinating on a global effort to end the cross-border games that allow companies to avoid taxation by moving money among various subsidiaries. Multinational corporations are especially worried about losing access to Cayman Island-style tax rates in European countries where they can also get rule of law, political stability and an educated professional class of attorneys and consultants.

Now that they are feeling the sting from foreign tax crackdowns, giant corporations and their Washington lobbyists are pressing Congress to cut them a new sweetheart deal here at home. But instead of bailing out the tax dodgers under the guise of tax reform, Congress should seize this moment to take three crucial steps to repair our broken corporate tax code.

In the 1950s, corporations contributed about $3 out of every $10 in federal revenue. Today they contribute $1 out of every $10, despite their reliance on federal investments to start and expand their businesses. The National Science Foundation helped fund some of the initial work of Google’s founders. Apple’s consumer products still rely on technology that originated in federally funded research.

(the federal govt. and its research and dev. spending is directly or indirectly responsible for literally trillion$ of GDP and millions of jobs)

Congress should level the playing field for small businesses. Small companies in Massachusetts don’t stash profits in the Netherlands. They can’t hire a team of accountants to set up a “reverse hybrid mismatch” to slash their taxes. This puts small businesses at a competitive disadvantage as they end up shouldering more of the burden of paying for education, infrastructure, research, the military and everything else our nation relies on to succeed.

And they ALL pay lip service on how it is small businesses that create most new jobs but then act in congress to kill them with an unbalanced tax regime.

HERE

_____________________________

You can be a murderous tyrant and the world will remember you fondly but fuck one horse and you will be a horse fucker for all eternity. Catherine the Great

Under capitalism, man exploits man. Under communism, it's just the opposite.
J K Galbraith
Profile   Post #: 1
RE: Tax havens could be on the way out - 9/9/2016 5:32:46 PM   
Termyn8or


Posts: 18681
Joined: 11/12/2005
Status: offline
We know. Call me when you got enough bribe money to fix it.

I say the People need to fight them. Drive the same car until it literally falls apart, and then buy a used one. No new houses, furniture, even clothes as long as you can. KILL this fucking economy, especially in the big buck things. Pay a little more and go to the Convenient, pay Hak Na Gok a few extra pennies amd have Gint this and Mega that fucking starve. Do NOTHING to stimulate the economy.

And do it while it is still a choice and you at lead have some money, because if you wait too long you will have no money and no choice. You will be in a worse position than if you act now. Stop the economy. Stop all automatic bill pays and take most of your money out of the banks and the stack market. Show them that you aren't a patsy anymore. Let it all collapse while you still have something. Stock up on food and water. Get a generator and fuel to run it. Get guns, and stock up on precious metals, not those worthless gold certificates.

The only way to stop these motherfuckers is to remove their profit. If they don't make money they go away. The guns ? Well they have no skills and might just try to take your shit by force, they will have no other choice.

Don't start a revolution or anything of the sort, let them come to you.

T^T

(in reply to MrRodgers)
Profile   Post #: 2
RE: Tax havens could be on the way out - 9/9/2016 5:35:44 PM   
Lucylastic


Posts: 40310
Status: offline
FR Tax havens banned? I cant see it happening. But I would LOVE to see it happen, it needs to happen.



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(in reply to Termyn8or)
Profile   Post #: 3
RE: Tax havens could be on the way out - 9/9/2016 5:51:10 PM   
Termyn8or


Posts: 18681
Joined: 11/12/2005
Status: offline
They got an INDOOR ski range in Dubai. How could they pay for that without evading taxes ? Poor babies.

T^T

(in reply to Lucylastic)
Profile   Post #: 4
RE: Tax havens could be on the way out - 9/9/2016 6:07:05 PM   
Diffident


Posts: 163
Joined: 7/12/2016
Status: offline
Unfortunately, the people and corporations who benefit from tax havens have too much influence over the people who make the laws. Until that changes don't expect to see anything more than small deals that are enough to make headlines and make people think that they are taking it seriously, but which don't really fundamentally changing anything in practice.

(in reply to Termyn8or)
Profile   Post #: 5
RE: Tax havens could be on the way out - 9/9/2016 8:37:15 PM   
Real0ne


Posts: 21189
Joined: 10/25/2004
Status: offline
hence nothing ever changes
but it was a great show

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Yesterdays tinfoil is today's reality!

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(in reply to Diffident)
Profile   Post #: 6
RE: Tax havens could be on the way out - 9/9/2016 11:29:59 PM   
tj444


Posts: 7574
Joined: 3/7/2010
Status: offline

quote:

ORIGINAL: MrRodgers

Highlites or...lowlites:

.....the European Commission ordered Ireland to collect more than $14 billion in back taxes from the company. (Apple) The global giant had been attributing billions of dollars in profits to a phantom head office, allowing it to pay a tax rate of 1 percent or lower.

Both Apple and Ireland are appealing the decision, but the commission’s announcement was the latest sign that multinational corporations are running out of places to hide from paying taxes. The door is now open for Congress to fix our own corporate tax code, which has allowed the biggest multinationals to shirk their obligations for decades.

The European Commission is investigating Luxembourg’s tax arrangements for Amazon and McDonald’s, and last year the European Court of Justice struck down tax advantages to companies and their subsidiaries selling e-books throughout Europe. Also last year, Britain enacted a new tax to target profits siphoned off by international companies, nicknamed, without much subtlety, the “Google tax.”

The Organization for Economic Cooperation and Development and the Group of 20 nations are coordinating on a global effort to end the cross-border games that allow companies to avoid taxation by moving money among various subsidiaries. Multinational corporations are especially worried about losing access to Cayman Island-style tax rates in European countries where they can also get rule of law, political stability and an educated professional class of attorneys and consultants.

Now that they are feeling the sting from foreign tax crackdowns, giant corporations and their Washington lobbyists are pressing Congress to cut them a new sweetheart deal here at home. But instead of bailing out the tax dodgers under the guise of tax reform, Congress should seize this moment to take three crucial steps to repair our broken corporate tax code.

In the 1950s, corporations contributed about $3 out of every $10 in federal revenue. Today they contribute $1 out of every $10, despite their reliance on federal investments to start and expand their businesses. The National Science Foundation helped fund some of the initial work of Google’s founders. Apple’s consumer products still rely on technology that originated in federally funded research.

(the federal govt. and its research and dev. spending is directly or indirectly responsible for literally trillion$ of GDP and millions of jobs)

Congress should level the playing field for small businesses. Small companies in Massachusetts don’t stash profits in the Netherlands. They can’t hire a team of accountants to set up a “reverse hybrid mismatch” to slash their taxes. This puts small businesses at a competitive disadvantage as they end up shouldering more of the burden of paying for education, infrastructure, research, the military and everything else our nation relies on to succeed.

And they ALL pay lip service on how it is small businesses that create most new jobs but then act in congress to kill them with an unbalanced tax regime.

HERE

" international tax shell game".. what bull shite!

Look in the god damn mirror! I find it awfully interesting that the focus is on other countries when the good ole US of A has many states that are set up as tax havens.. where is the outcry here about that then??? what a f'n bunch of hypocrites! Do you forget that Google, Microsoft and all those big US corps negotiate secret deals with the IRS to pay about half the rate small and medium sized businesses must pay??? Who the hell needs international tax havens when you dont even need to leave home?? Btw, you can form a company in certain states without anyone knowing who the true owners of that company are.. The US is the biggest tax haven going..

"The tax break that corporate America wants kept secret
Oracle, Google, and Amazon are just a few of the hundreds of large companies that have cut confidential deals with the IRS to help lower their tax bills, and critics want the agency to disclose the details of these complex pacts.
FORTUNE — When Oracle reported its latest quarterly earnings last month, most investors focused on the fact that its dividend doubled. The number that got less notice in its annual report a week later was its low tax bill — nearly half the standard 35% corporate rate.
It’s a significant change from a decade ago, when the software giant began thinking about higher tax costs amid plans for growth. It turned to an obscure solution: confidential pacts forged between the Internal Revenue Service and multinational corporations that critics say can unwittingly bless aggressive tax strategies. In 2003 Oracle disclosed for the first time that it had sealed two such long-term pacts with the IRS and was negotiating additional ones.
The pacts, known as advance pricing agreements, effectively lock the IRS into agreeing with a company’s tax planning over many years, both future and past. Despite costing companies up to millions of dollars in fees to prepare and taking up to four years to seal, the agreements are nonetheless worth it to an elite group of big corporations that have them, including Google GOOG 1.37% , Apple AAPL 0.29% , and Amazon AMZN 1.07% .
The inner workings of the pacts, whose effects are sometimes not seen until years later, are not disclosed due to taxpayer confidentiality laws. Oracle ORCL -0.22% has not been accused of any wrongdoing. Still, the deals appear to have worked for the company: In fiscal 2003, its company’s tax rate was 32%, reflecting $1.1 billion in cash income taxes paid to federal, state, local, and foreign collectors, on pre-tax income of more than $3.4 billion, securities filings show.
Fast-forward a decade, over which Oracle finalized four more pacts, including two governing foreign tax benefits, generally covering fiscal years 2002 through 2013, excepting 2006. It also consolidated hundreds of offshore subsidiaries into six core affiliates in Ireland, and by this year had amassed $26 billion in cash held overseas — more than seven times 2003’s level. As of May, when its 2013 fiscal year ended, Oracle had nearly halved its tax bill. It paid $2.6 billion in cash income taxes on pre-tax income of nearly $13.9 billion, a rate of just under 19%.
Jessica Moore, a spokeswoman for Oracle, declined to respond to questions about its tax deals.
Widening scrutiny of declining corporate tax bills has singled out the growing use of post office-box subsidiaries in offshore tax havens to hoard cash stockpiles and whisk profits away from higher-tax jurisdictions. Now some experts wonder if advance pricing agreements, perfectly legal under U.S. law and growing in number, sometimes play a major role in helping to shift some of those profits and drive down corporate tax bills.
There’s a lot of confidential information in these deals, because it’s where companies make their profits,” said Patricia Lewis, a tax lawyer at Caplin & Drysdale who helps companies negotiate the pacts."


http://fortune.com/2013/07/22/the-tax-break-that-corporate-america-wants-kept-secret/

_____________________________

As Anderson Cooper said “If he (Trump) took a dump on his desk, you would defend it”

(in reply to MrRodgers)
Profile   Post #: 7
RE: Tax havens could be on the way out - 9/10/2016 12:25:01 AM   
MrRodgers


Posts: 10542
Joined: 7/30/2005
Status: offline
quote:

ORIGINAL: tj444


quote:

ORIGINAL: MrRodgers

Highlites or...lowlites:

.....the European Commission ordered Ireland to collect more than $14 billion in back taxes from the company. (Apple) The global giant had been attributing billions of dollars in profits to a phantom head office, allowing it to pay a tax rate of 1 percent or lower.

Both Apple and Ireland are appealing the decision, but the commission’s announcement was the latest sign that multinational corporations are running out of places to hide from paying taxes. The door is now open for Congress to fix our own corporate tax code, which has allowed the biggest multinationals to shirk their obligations for decades.

The European Commission is investigating Luxembourg’s tax arrangements for Amazon and McDonald’s, and last year the European Court of Justice struck down tax advantages to companies and their subsidiaries selling e-books throughout Europe. Also last year, Britain enacted a new tax to target profits siphoned off by international companies, nicknamed, without much subtlety, the “Google tax.”

The Organization for Economic Cooperation and Development and the Group of 20 nations are coordinating on a global effort to end the cross-border games that allow companies to avoid taxation by moving money among various subsidiaries. Multinational corporations are especially worried about losing access to Cayman Island-style tax rates in European countries where they can also get rule of law, political stability and an educated professional class of attorneys and consultants.

Now that they are feeling the sting from foreign tax crackdowns, giant corporations and their Washington lobbyists are pressing Congress to cut them a new sweetheart deal here at home. But instead of bailing out the tax dodgers under the guise of tax reform, Congress should seize this moment to take three crucial steps to repair our broken corporate tax code.

In the 1950s, corporations contributed about $3 out of every $10 in federal revenue. Today they contribute $1 out of every $10, despite their reliance on federal investments to start and expand their businesses. The National Science Foundation helped fund some of the initial work of Google’s founders. Apple’s consumer products still rely on technology that originated in federally funded research.

(the federal govt. and its research and dev. spending is directly or indirectly responsible for literally trillion$ of GDP and millions of jobs)

Congress should level the playing field for small businesses. Small companies in Massachusetts don’t stash profits in the Netherlands. They can’t hire a team of accountants to set up a “reverse hybrid mismatch” to slash their taxes. This puts small businesses at a competitive disadvantage as they end up shouldering more of the burden of paying for education, infrastructure, research, the military and everything else our nation relies on to succeed.

And they ALL pay lip service on how it is small businesses that create most new jobs but then act in congress to kill them with an unbalanced tax regime.

HERE

" international tax shell game".. what bull shite!

Look in the god damn mirror! I find it awfully interesting that the focus is on other countries when the good ole US of A has many states that are set up as tax havens.. where is the outcry here about that then??? what a f'n bunch of hypocrites! Do you forget that Google, Microsoft and all those big US corps negotiate secret deals with the IRS to pay about half the rate small and medium sized businesses must pay??? Who the hell needs international tax havens when you dont even need to leave home?? Btw, you can form a company in certain states without anyone knowing who the true owners of that company are.. The US is the biggest tax haven going..

"The tax break that corporate America wants kept secret
Oracle, Google, and Amazon are just a few of the hundreds of large companies that have cut confidential deals with the IRS to help lower their tax bills, and critics want the agency to disclose the details of these complex pacts.
FORTUNE — When Oracle reported its latest quarterly earnings last month, most investors focused on the fact that its dividend doubled. The number that got less notice in its annual report a week later was its low tax bill — nearly half the standard 35% corporate rate.
It’s a significant change from a decade ago, when the software giant began thinking about higher tax costs amid plans for growth. It turned to an obscure solution: confidential pacts forged between the Internal Revenue Service and multinational corporations that critics say can unwittingly bless aggressive tax strategies. In 2003 Oracle disclosed for the first time that it had sealed two such long-term pacts with the IRS and was negotiating additional ones.
The pacts, known as advance pricing agreements, effectively lock the IRS into agreeing with a company’s tax planning over many years, both future and past. Despite costing companies up to millions of dollars in fees to prepare and taking up to four years to seal, the agreements are nonetheless worth it to an elite group of big corporations that have them, including Google GOOG 1.37% , Apple AAPL 0.29% , and Amazon AMZN 1.07% .
The inner workings of the pacts, whose effects are sometimes not seen until years later, are not disclosed due to taxpayer confidentiality laws. Oracle ORCL -0.22% has not been accused of any wrongdoing. Still, the deals appear to have worked for the company: In fiscal 2003, its company’s tax rate was 32%, reflecting $1.1 billion in cash income taxes paid to federal, state, local, and foreign collectors, on pre-tax income of more than $3.4 billion, securities filings show.
Fast-forward a decade, over which Oracle finalized four more pacts, including two governing foreign tax benefits, generally covering fiscal years 2002 through 2013, excepting 2006. It also consolidated hundreds of offshore subsidiaries into six core affiliates in Ireland, and by this year had amassed $26 billion in cash held overseas — more than seven times 2003’s level. As of May, when its 2013 fiscal year ended, Oracle had nearly halved its tax bill. It paid $2.6 billion in cash income taxes on pre-tax income of nearly $13.9 billion, a rate of just under 19%.
Jessica Moore, a spokeswoman for Oracle, declined to respond to questions about its tax deals.
Widening scrutiny of declining corporate tax bills has singled out the growing use of post office-box subsidiaries in offshore tax havens to hoard cash stockpiles and whisk profits away from higher-tax jurisdictions. Now some experts wonder if advance pricing agreements, perfectly legal under U.S. law and growing in number, sometimes play a major role in helping to shift some of those profits and drive down corporate tax bills.
There’s a lot of confidential information in these deals, because it’s where companies make their profits,” said Patricia Lewis, a tax lawyer at Caplin & Drysdale who helps companies negotiate the pacts."


http://fortune.com/2013/07/22/the-tax-break-that-corporate-america-wants-kept-secret/

Old news, the OP is a recent very ruling that has far more effect on corporate taxes when we all know and have known for some time, that the effective US tax rates has been substantially less then the statutory 35%.

Plus the lawyer is wrong. These companies 'make their profits' from the sale of goods and services and what these tax 'negotiations' do is reduce the tax on those profits.

There is no hypocrisy here at all. They are two distinctly different tax regimes, one is domestic, the other an international attempt to rectify tax dodging and from what it reads, down to...almost ZERO. And OH, these rates in the OP make it VERY apparent why companies seek out these tax havens.

You are saying the IRS and these tax deals and American and some international tax law is corrupt...gee, we never knew that. Apple alone just got hit with $14 billion in new taxes. Now that's news.

< Message edited by MrRodgers -- 9/10/2016 12:31:26 AM >


_____________________________

You can be a murderous tyrant and the world will remember you fondly but fuck one horse and you will be a horse fucker for all eternity. Catherine the Great

Under capitalism, man exploits man. Under communism, it's just the opposite.
J K Galbraith

(in reply to tj444)
Profile   Post #: 8
RE: Tax havens could be on the way out - 9/10/2016 2:49:23 AM   
KenDckey


Posts: 4121
Joined: 5/31/2006
Status: offline
I believe that the purpose of Goverrnment is to tax business and people out of their profits. A business that produces goods and services that makes no profits serves no purpose. Oh, people are making a wage, but that itself is being challenged because of the tax burden. We even now must pay taxes on medical equipment and I expect sometime in the not to distant future that will expand. You make investments - taxes. I percieve government wanting to make all wages the same, regardless of the amount work produced, responsibility, etc. I see government wanting to tell us exactly how to live our lives. And I am not necesssarily refering to the US Government. I wonder how long it will take the UN to establish a global tax system to further erode society, taking it away from whatever national government says is needed.

(in reply to MrRodgers)
Profile   Post #: 9
RE: Tax havens could be on the way out - 9/10/2016 8:33:14 PM   
tj444


Posts: 7574
Joined: 3/7/2010
Status: offline

quote:

ORIGINAL: MrRodgers

quote:

ORIGINAL: tj444


quote:

ORIGINAL: MrRodgers

Highlites or...lowlites:

.....the European Commission ordered Ireland to collect more than $14 billion in back taxes from the company. (Apple) The global giant had been attributing billions of dollars in profits to a phantom head office, allowing it to pay a tax rate of 1 percent or lower.

Both Apple and Ireland are appealing the decision, but the commission’s announcement was the latest sign that multinational corporations are running out of places to hide from paying taxes. The door is now open for Congress to fix our own corporate tax code, which has allowed the biggest multinationals to shirk their obligations for decades.

The European Commission is investigating Luxembourg’s tax arrangements for Amazon and McDonald’s, and last year the European Court of Justice struck down tax advantages to companies and their subsidiaries selling e-books throughout Europe. Also last year, Britain enacted a new tax to target profits siphoned off by international companies, nicknamed, without much subtlety, the “Google tax.”

The Organization for Economic Cooperation and Development and the Group of 20 nations are coordinating on a global effort to end the cross-border games that allow companies to avoid taxation by moving money among various subsidiaries. Multinational corporations are especially worried about losing access to Cayman Island-style tax rates in European countries where they can also get rule of law, political stability and an educated professional class of attorneys and consultants.

Now that they are feeling the sting from foreign tax crackdowns, giant corporations and their Washington lobbyists are pressing Congress to cut them a new sweetheart deal here at home. But instead of bailing out the tax dodgers under the guise of tax reform, Congress should seize this moment to take three crucial steps to repair our broken corporate tax code.

In the 1950s, corporations contributed about $3 out of every $10 in federal revenue. Today they contribute $1 out of every $10, despite their reliance on federal investments to start and expand their businesses. The National Science Foundation helped fund some of the initial work of Google’s founders. Apple’s consumer products still rely on technology that originated in federally funded research.

(the federal govt. and its research and dev. spending is directly or indirectly responsible for literally trillion$ of GDP and millions of jobs)

Congress should level the playing field for small businesses. Small companies in Massachusetts don’t stash profits in the Netherlands. They can’t hire a team of accountants to set up a “reverse hybrid mismatch” to slash their taxes. This puts small businesses at a competitive disadvantage as they end up shouldering more of the burden of paying for education, infrastructure, research, the military and everything else our nation relies on to succeed.

And they ALL pay lip service on how it is small businesses that create most new jobs but then act in congress to kill them with an unbalanced tax regime.

HERE

" international tax shell game".. what bull shite!

Look in the god damn mirror! I find it awfully interesting that the focus is on other countries when the good ole US of A has many states that are set up as tax havens.. where is the outcry here about that then??? what a f'n bunch of hypocrites! Do you forget that Google, Microsoft and all those big US corps negotiate secret deals with the IRS to pay about half the rate small and medium sized businesses must pay??? Who the hell needs international tax havens when you dont even need to leave home?? Btw, you can form a company in certain states without anyone knowing who the true owners of that company are.. The US is the biggest tax haven going..

"The tax break that corporate America wants kept secret
Oracle, Google, and Amazon are just a few of the hundreds of large companies that have cut confidential deals with the IRS to help lower their tax bills, and critics want the agency to disclose the details of these complex pacts.
FORTUNE — When Oracle reported its latest quarterly earnings last month, most investors focused on the fact that its dividend doubled. The number that got less notice in its annual report a week later was its low tax bill — nearly half the standard 35% corporate rate.
It’s a significant change from a decade ago, when the software giant began thinking about higher tax costs amid plans for growth. It turned to an obscure solution: confidential pacts forged between the Internal Revenue Service and multinational corporations that critics say can unwittingly bless aggressive tax strategies. In 2003 Oracle disclosed for the first time that it had sealed two such long-term pacts with the IRS and was negotiating additional ones.
The pacts, known as advance pricing agreements, effectively lock the IRS into agreeing with a company’s tax planning over many years, both future and past. Despite costing companies up to millions of dollars in fees to prepare and taking up to four years to seal, the agreements are nonetheless worth it to an elite group of big corporations that have them, including Google GOOG 1.37% , Apple AAPL 0.29% , and Amazon AMZN 1.07% .
The inner workings of the pacts, whose effects are sometimes not seen until years later, are not disclosed due to taxpayer confidentiality laws. Oracle ORCL -0.22% has not been accused of any wrongdoing. Still, the deals appear to have worked for the company: In fiscal 2003, its company’s tax rate was 32%, reflecting $1.1 billion in cash income taxes paid to federal, state, local, and foreign collectors, on pre-tax income of more than $3.4 billion, securities filings show.
Fast-forward a decade, over which Oracle finalized four more pacts, including two governing foreign tax benefits, generally covering fiscal years 2002 through 2013, excepting 2006. It also consolidated hundreds of offshore subsidiaries into six core affiliates in Ireland, and by this year had amassed $26 billion in cash held overseas — more than seven times 2003’s level. As of May, when its 2013 fiscal year ended, Oracle had nearly halved its tax bill. It paid $2.6 billion in cash income taxes on pre-tax income of nearly $13.9 billion, a rate of just under 19%.
Jessica Moore, a spokeswoman for Oracle, declined to respond to questions about its tax deals.
Widening scrutiny of declining corporate tax bills has singled out the growing use of post office-box subsidiaries in offshore tax havens to hoard cash stockpiles and whisk profits away from higher-tax jurisdictions. Now some experts wonder if advance pricing agreements, perfectly legal under U.S. law and growing in number, sometimes play a major role in helping to shift some of those profits and drive down corporate tax bills.
There’s a lot of confidential information in these deals, because it’s where companies make their profits,” said Patricia Lewis, a tax lawyer at Caplin & Drysdale who helps companies negotiate the pacts."


http://fortune.com/2013/07/22/the-tax-break-that-corporate-america-wants-kept-secret/

Old news, the OP is a recent very ruling that has far more effect on corporate taxes when we all know and have known for some time, that the effective US tax rates has been substantially less then the statutory 35%.

Plus the lawyer is wrong. These companies 'make their profits' from the sale of goods and services and what these tax 'negotiations' do is reduce the tax on those profits.

There is no hypocrisy here at all. They are two distinctly different tax regimes, one is domestic, the other an international attempt to rectify tax dodging and from what it reads, down to...almost ZERO. And OH, these rates in the OP make it VERY apparent why companies seek out these tax havens.

You are saying the IRS and these tax deals and American and some international tax law is corrupt...gee, we never knew that. Apple alone just got hit with $14 billion in new taxes. Now that's news.

I dont give a shite if you think US tax havens and secret half-price deals with the IRS are "old news" or not (most Americans dont even have a clue this goes on here in the good ole US of A), its not fair to small & medium businesses that do pay their fair share of tax that they have to compete with sleazy big corps that can afford the lawyers and get 50% off their taxes.. and I will continue to point out American hypocricy until that changes (or hell freezes over)..

_____________________________

As Anderson Cooper said “If he (Trump) took a dump on his desk, you would defend it”

(in reply to MrRodgers)
Profile   Post #: 10
RE: Tax havens could be on the way out - 9/10/2016 10:48:23 PM   
MrRodgers


Posts: 10542
Joined: 7/30/2005
Status: offline

quote:

ORIGINAL: tj444


quote:

ORIGINAL: MrRodgers

quote:

ORIGINAL: tj444


quote:

ORIGINAL: MrRodgers

Highlites or...lowlites:

.....the European Commission ordered Ireland to collect more than $14 billion in back taxes from the company. (Apple) The global giant had been attributing billions of dollars in profits to a phantom head office, allowing it to pay a tax rate of 1 percent or lower.

Both Apple and Ireland are appealing the decision, but the commission’s announcement was the latest sign that multinational corporations are running out of places to hide from paying taxes. The door is now open for Congress to fix our own corporate tax code, which has allowed the biggest multinationals to shirk their obligations for decades.

The European Commission is investigating Luxembourg’s tax arrangements for Amazon and McDonald’s, and last year the European Court of Justice struck down tax advantages to companies and their subsidiaries selling e-books throughout Europe. Also last year, Britain enacted a new tax to target profits siphoned off by international companies, nicknamed, without much subtlety, the “Google tax.”

The Organization for Economic Cooperation and Development and the Group of 20 nations are coordinating on a global effort to end the cross-border games that allow companies to avoid taxation by moving money among various subsidiaries. Multinational corporations are especially worried about losing access to Cayman Island-style tax rates in European countries where they can also get rule of law, political stability and an educated professional class of attorneys and consultants.

Now that they are feeling the sting from foreign tax crackdowns, giant corporations and their Washington lobbyists are pressing Congress to cut them a new sweetheart deal here at home. But instead of bailing out the tax dodgers under the guise of tax reform, Congress should seize this moment to take three crucial steps to repair our broken corporate tax code.

In the 1950s, corporations contributed about $3 out of every $10 in federal revenue. Today they contribute $1 out of every $10, despite their reliance on federal investments to start and expand their businesses. The National Science Foundation helped fund some of the initial work of Google’s founders. Apple’s consumer products still rely on technology that originated in federally funded research.

(the federal govt. and its research and dev. spending is directly or indirectly responsible for literally trillion$ of GDP and millions of jobs)

Congress should level the playing field for small businesses. Small companies in Massachusetts don’t stash profits in the Netherlands. They can’t hire a team of accountants to set up a “reverse hybrid mismatch” to slash their taxes. This puts small businesses at a competitive disadvantage as they end up shouldering more of the burden of paying for education, infrastructure, research, the military and everything else our nation relies on to succeed.

And they ALL pay lip service on how it is small businesses that create most new jobs but then act in congress to kill them with an unbalanced tax regime.

HERE

" international tax shell game".. what bull shite!

Look in the god damn mirror! I find it awfully interesting that the focus is on other countries when the good ole US of A has many states that are set up as tax havens.. where is the outcry here about that then??? what a f'n bunch of hypocrites! Do you forget that Google, Microsoft and all those big US corps negotiate secret deals with the IRS to pay about half the rate small and medium sized businesses must pay??? Who the hell needs international tax havens when you dont even need to leave home?? Btw, you can form a company in certain states without anyone knowing who the true owners of that company are.. The US is the biggest tax haven going..

"The tax break that corporate America wants kept secret
Oracle, Google, and Amazon are just a few of the hundreds of large companies that have cut confidential deals with the IRS to help lower their tax bills, and critics want the agency to disclose the details of these complex pacts.
FORTUNE — When Oracle reported its latest quarterly earnings last month, most investors focused on the fact that its dividend doubled. The number that got less notice in its annual report a week later was its low tax bill — nearly half the standard 35% corporate rate.
It’s a significant change from a decade ago, when the software giant began thinking about higher tax costs amid plans for growth. It turned to an obscure solution: confidential pacts forged between the Internal Revenue Service and multinational corporations that critics say can unwittingly bless aggressive tax strategies. In 2003 Oracle disclosed for the first time that it had sealed two such long-term pacts with the IRS and was negotiating additional ones.
The pacts, known as advance pricing agreements, effectively lock the IRS into agreeing with a company’s tax planning over many years, both future and past. Despite costing companies up to millions of dollars in fees to prepare and taking up to four years to seal, the agreements are nonetheless worth it to an elite group of big corporations that have them, including Google GOOG 1.37% , Apple AAPL 0.29% , and Amazon AMZN 1.07% .
The inner workings of the pacts, whose effects are sometimes not seen until years later, are not disclosed due to taxpayer confidentiality laws. Oracle ORCL -0.22% has not been accused of any wrongdoing. Still, the deals appear to have worked for the company: In fiscal 2003, its company’s tax rate was 32%, reflecting $1.1 billion in cash income taxes paid to federal, state, local, and foreign collectors, on pre-tax income of more than $3.4 billion, securities filings show.
Fast-forward a decade, over which Oracle finalized four more pacts, including two governing foreign tax benefits, generally covering fiscal years 2002 through 2013, excepting 2006. It also consolidated hundreds of offshore subsidiaries into six core affiliates in Ireland, and by this year had amassed $26 billion in cash held overseas — more than seven times 2003’s level. As of May, when its 2013 fiscal year ended, Oracle had nearly halved its tax bill. It paid $2.6 billion in cash income taxes on pre-tax income of nearly $13.9 billion, a rate of just under 19%.
Jessica Moore, a spokeswoman for Oracle, declined to respond to questions about its tax deals.
Widening scrutiny of declining corporate tax bills has singled out the growing use of post office-box subsidiaries in offshore tax havens to hoard cash stockpiles and whisk profits away from higher-tax jurisdictions. Now some experts wonder if advance pricing agreements, perfectly legal under U.S. law and growing in number, sometimes play a major role in helping to shift some of those profits and drive down corporate tax bills.
There’s a lot of confidential information in these deals, because it’s where companies make their profits,” said Patricia Lewis, a tax lawyer at Caplin & Drysdale who helps companies negotiate the pacts."


http://fortune.com/2013/07/22/the-tax-break-that-corporate-america-wants-kept-secret/

Old news, the OP is a recent very ruling that has far more effect on corporate taxes when we all know and have known for some time, that the effective US tax rates has been substantially less then the statutory 35%.

Plus the lawyer is wrong. These companies 'make their profits' from the sale of goods and services and what these tax 'negotiations' do is reduce the tax on those profits.

There is no hypocrisy here at all. They are two distinctly different tax regimes, one is domestic, the other an international attempt to rectify tax dodging and from what it reads, down to...almost ZERO. And OH, these rates in the OP make it VERY apparent why companies seek out these tax havens.

You are saying the IRS and these tax deals and American and some international tax law is corrupt...gee, we never knew that. Apple alone just got hit with $14 billion in new taxes. Now that's news.

I dont give a shite if you think US tax havens and secret half-price deals with the IRS are "old news" or not (most Americans dont even have a clue this goes on here in the good ole US of A), its not fair to small & medium businesses that do pay their fair share of tax that they have to compete with sleazy big corps that can afford the lawyers and get 50% off their taxes.. and I will continue to point out American hypocricy until that changes (or hell freezes over)..

I understand where you are coming but many American are aware that corps. pay 1/2 or less of the actual tax code corp. rate but maybe, just maybe, this new tax on Apple from the EU is just the first salvo in a long movement that might help make people more aware of the whole of the immorality of corporations, these tax deals and the inherent corruption and may inspire a slow reform.

One can only hope.

_____________________________

You can be a murderous tyrant and the world will remember you fondly but fuck one horse and you will be a horse fucker for all eternity. Catherine the Great

Under capitalism, man exploits man. Under communism, it's just the opposite.
J K Galbraith

(in reply to tj444)
Profile   Post #: 11
RE: Tax havens could be on the way out - 9/12/2016 6:47:27 AM   
DesideriScuri


Posts: 12225
Joined: 1/18/2012
Status: offline
quote:

ORIGINAL: MrRodgers
I understand where you are coming but many American are aware that corps. pay 1/2 or less of the actual tax code corp. rate but maybe, just maybe, this new tax on Apple from the EU is just the first salvo in a long movement that might help make people more aware of the whole of the immorality of corporations, these tax deals and the inherent corruption and may inspire a slow reform.
One can only hope.


Yet, the US has a reciprocity agreement that multinationals can write off portions of their US taxes. Multinationals pay taxes on their profits in whatever country they are earned. Any profits brought back to the US gets taxed to the US, but the amount of that taxes is reduced by whatever they paid out in taxes already. So, if Apple (completely hypothetical numbers, btw) earned a profit of $1B on Christmas Island and paid $200M in taxes on that profit, and repatriates those profits, their tax bill will be whatever rate they manage here, less the $200M. So, Apple's $14B smack just might end up reducing Apple's taxes to the US anyway.


_____________________________

What I support:

  • A Conservative interpretation of the US Constitution
  • Personal Responsibility
  • Help for the truly needy
  • Limited Government
  • Consumption Tax (non-profit charities and food exempt)

(in reply to MrRodgers)
Profile   Post #: 12
RE: Tax havens could be on the way out - 9/12/2016 9:38:07 AM   
MrRodgers


Posts: 10542
Joined: 7/30/2005
Status: offline

quote:

ORIGINAL: DesideriScuri

quote:

ORIGINAL: MrRodgers
I understand where you are coming but many American are aware that corps. pay 1/2 or less of the actual tax code corp. rate but maybe, just maybe, this new tax on Apple from the EU is just the first salvo in a long movement that might help make people more aware of the whole of the immorality of corporations, these tax deals and the inherent corruption and may inspire a slow reform.
One can only hope.


Yet, the US has a reciprocity agreement that multinationals can write off portions of their US taxes. Multinationals pay taxes on their profits in whatever country they are earned. Any profits brought back to the US gets taxed to the US, but the amount of that taxes is reduced by whatever they paid out in taxes already. So, if Apple (completely hypothetical numbers, btw) earned a profit of $1B on Christmas Island and paid $200M in taxes on that profit, and repatriates those profits, their tax bill will be whatever rate they manage here, less the $200M. So, Apple's $14B smack just might end up reducing Apple's taxes to the US anyway.


You would be correct but obviously as I am sure you understand, with that new tax hit ruled by the EC now due in Ireland and should it stick (under appeal) there will be no more incentive to report them there and should otherwise just bring those profits 'home' anyway.

Let's say for example Apple did bring those profits back to the US. they are now lobbying for a US rate that would reflect a lower tax bite than that now in Ireland. My whole problem with the US tax regime is experience.

Actual corp. tax rates and the effective tax rates, what they actually end up paying, is at a 60 year low (or longer) and that has not served the economy over all or society at large...at all. If fact if one goes back to about that time, corporate America has reduced their American employment ever since.

_____________________________

You can be a murderous tyrant and the world will remember you fondly but fuck one horse and you will be a horse fucker for all eternity. Catherine the Great

Under capitalism, man exploits man. Under communism, it's just the opposite.
J K Galbraith

(in reply to DesideriScuri)
Profile   Post #: 13
RE: Tax havens could be on the way out - 9/12/2016 2:16:27 PM   
DesideriScuri


Posts: 12225
Joined: 1/18/2012
Status: offline
quote:

ORIGINAL: MrRodgers
quote:

ORIGINAL: DesideriScuri
quote:

ORIGINAL: MrRodgers
I understand where you are coming but many American are aware that corps. pay 1/2 or less of the actual tax code corp. rate but maybe, just maybe, this new tax on Apple from the EU is just the first salvo in a long movement that might help make people more aware of the whole of the immorality of corporations, these tax deals and the inherent corruption and may inspire a slow reform.
One can only hope.

Yet, the US has a reciprocity agreement that multinationals can write off portions of their US taxes. Multinationals pay taxes on their profits in whatever country they are earned. Any profits brought back to the US gets taxed to the US, but the amount of that taxes is reduced by whatever they paid out in taxes already. So, if Apple (completely hypothetical numbers, btw) earned a profit of $1B on Christmas Island and paid $200M in taxes on that profit, and repatriates those profits, their tax bill will be whatever rate they manage here, less the $200M. So, Apple's $14B smack just might end up reducing Apple's taxes to the US anyway.

You would be correct but obviously as I am sure you understand, with that new tax hit ruled by the EC now due in Ireland and should it stick (under appeal) there will be no more incentive to report them there and should otherwise just bring those profits 'home' anyway.
Let's say for example Apple did bring those profits back to the US. they are now lobbying for a US rate that would reflect a lower tax bite than that now in Ireland. My whole problem with the US tax regime is experience.
Actual corp. tax rates and the effective tax rates, what they actually end up paying, is at a 60 year low (or longer) and that has not served the economy over all or society at large...at all. If fact if one goes back to about that time, corporate America has reduced their American employment ever since.


Why should Corporations pay taxes on money that isn't brought back to the US? If they make a profit in, say, Laos and use that money outside the US, why should they have to pay US taxes on it?


_____________________________

What I support:

  • A Conservative interpretation of the US Constitution
  • Personal Responsibility
  • Help for the truly needy
  • Limited Government
  • Consumption Tax (non-profit charities and food exempt)

(in reply to MrRodgers)
Profile   Post #: 14
RE: Tax havens could be on the way out - 9/12/2016 2:29:00 PM   
mnottertail


Posts: 60698
Joined: 11/3/2004
Status: offline
Thats fine as well, but you cannot expect the laws and benefits of the USA to be yours if you aren't putting back. Let them move to Guam.

_____________________________

Have they not divided the prey; to every man a damsel or two? Judges 5:30


(in reply to DesideriScuri)
Profile   Post #: 15
RE: Tax havens could be on the way out - 9/12/2016 9:50:18 PM   
tj444


Posts: 7574
Joined: 3/7/2010
Status: offline

quote:

ORIGINAL: DesideriScuri

quote:

ORIGINAL: MrRodgers
quote:

ORIGINAL: DesideriScuri
quote:

ORIGINAL: MrRodgers
I understand where you are coming but many American are aware that corps. pay 1/2 or less of the actual tax code corp. rate but maybe, just maybe, this new tax on Apple from the EU is just the first salvo in a long movement that might help make people more aware of the whole of the immorality of corporations, these tax deals and the inherent corruption and may inspire a slow reform.
One can only hope.

Yet, the US has a reciprocity agreement that multinationals can write off portions of their US taxes. Multinationals pay taxes on their profits in whatever country they are earned. Any profits brought back to the US gets taxed to the US, but the amount of that taxes is reduced by whatever they paid out in taxes already. So, if Apple (completely hypothetical numbers, btw) earned a profit of $1B on Christmas Island and paid $200M in taxes on that profit, and repatriates those profits, their tax bill will be whatever rate they manage here, less the $200M. So, Apple's $14B smack just might end up reducing Apple's taxes to the US anyway.

You would be correct but obviously as I am sure you understand, with that new tax hit ruled by the EC now due in Ireland and should it stick (under appeal) there will be no more incentive to report them there and should otherwise just bring those profits 'home' anyway.
Let's say for example Apple did bring those profits back to the US. they are now lobbying for a US rate that would reflect a lower tax bite than that now in Ireland. My whole problem with the US tax regime is experience.
Actual corp. tax rates and the effective tax rates, what they actually end up paying, is at a 60 year low (or longer) and that has not served the economy over all or society at large...at all. If fact if one goes back to about that time, corporate America has reduced their American employment ever since.


Why should Corporations pay taxes on money that isn't brought back to the US? If they make a profit in, say, Laos and use that money outside the US, why should they have to pay US taxes on it?



cuz every American ex-pat must file tax returns with the IRS and pay taxes on their non-US income (if over a certain amount) so why should big US corps get a free pass when Americans dont? as it is, they already get a free pass since they arent taxed like you would be, they can keep their profit offshore and tax-free from the IRS, while you would still be taxed no matter where you kept your income..

_____________________________

As Anderson Cooper said “If he (Trump) took a dump on his desk, you would defend it”

(in reply to DesideriScuri)
Profile   Post #: 16
RE: Tax havens could be on the way out - 9/12/2016 10:04:29 PM   
MrRodgers


Posts: 10542
Joined: 7/30/2005
Status: offline

quote:

ORIGINAL: DesideriScuri

quote:

ORIGINAL: MrRodgers
quote:

ORIGINAL: DesideriScuri
quote:

ORIGINAL: MrRodgers
I understand where you are coming but many American are aware that corps. pay 1/2 or less of the actual tax code corp. rate but maybe, just maybe, this new tax on Apple from the EU is just the first salvo in a long movement that might help make people more aware of the whole of the immorality of corporations, these tax deals and the inherent corruption and may inspire a slow reform.
One can only hope.

Yet, the US has a reciprocity agreement that multinationals can write off portions of their US taxes. Multinationals pay taxes on their profits in whatever country they are earned. Any profits brought back to the US gets taxed to the US, but the amount of that taxes is reduced by whatever they paid out in taxes already. So, if Apple (completely hypothetical numbers, btw) earned a profit of $1B on Christmas Island and paid $200M in taxes on that profit, and repatriates those profits, their tax bill will be whatever rate they manage here, less the $200M. So, Apple's $14B smack just might end up reducing Apple's taxes to the US anyway.

You would be correct but obviously as I am sure you understand, with that new tax hit ruled by the EC now due in Ireland and should it stick (under appeal) there will be no more incentive to report them there and should otherwise just bring those profits 'home' anyway.
Let's say for example Apple did bring those profits back to the US. they are now lobbying for a US rate that would reflect a lower tax bite than that now in Ireland. My whole problem with the US tax regime is experience.
Actual corp. tax rates and the effective tax rates, what they actually end up paying, is at a 60 year low (or longer) and that has not served the economy over all or society at large...at all. If fact if one goes back to about that time, corporate America has reduced their American employment ever since.


Why should Corporations pay taxes on money that isn't brought back to the US? If they make a profit in, say, Laos and use that money outside the US, why should they have to pay US taxes on it?


But that misses the point entirely. Those profits are made here and simply recorded in Ireland at a scam office there. It's called profit shifting. And to the extent the US tax offices are cracking down it, there is the rush now to tax inversion, or corporate inversion, is the practice of relocating a corporation's legal domicile to a lower-tax nation, or tax haven, usually while retaining its material operations in its higher-tax country of origin.

There are bldgs, in Ireland and the Caymans that are a few floors with a few offices where several hundred companies list offices but have no personnel while having a RA or registered agent hired to facilitate the scam and only for tax avoidance.

Furthermore, if taxes paid in Ireland are written off in the US, that amounts to a US tax code subsidy to Ireland. So the US taxpayer is hurt twice. If they don't want to get twice, the bring the profits home. What has always been needed and may be happening finally, is for the G20 to get together and construct an even playing field for all corp. taxes.

_____________________________

You can be a murderous tyrant and the world will remember you fondly but fuck one horse and you will be a horse fucker for all eternity. Catherine the Great

Under capitalism, man exploits man. Under communism, it's just the opposite.
J K Galbraith

(in reply to DesideriScuri)
Profile   Post #: 17
RE: Tax havens could be on the way out - 9/13/2016 6:43:24 AM   
DesideriScuri


Posts: 12225
Joined: 1/18/2012
Status: offline
quote:

ORIGINAL: tj444
quote:

ORIGINAL: DesideriScuri
Why should Corporations pay taxes on money that isn't brought back to the US? If they make a profit in, say, Laos and use that money outside the US, why should they have to pay US taxes on it?

cuz every American ex-pat must file tax returns with the IRS and pay taxes on their non-US income (if over a certain amount) so why should big US corps get a free pass when Americans dont? as it is, they already get a free pass since they arent taxed like you would be, they can keep their profit offshore and tax-free from the IRS, while you would still be taxed no matter where you kept your income..


It's telling that your response to an "unfair" situation, is not to end the expat tax, but to impose it on corporations, too.



_____________________________

What I support:

  • A Conservative interpretation of the US Constitution
  • Personal Responsibility
  • Help for the truly needy
  • Limited Government
  • Consumption Tax (non-profit charities and food exempt)

(in reply to tj444)
Profile   Post #: 18
RE: Tax havens could be on the way out - 9/13/2016 6:48:35 AM   
DesideriScuri


Posts: 12225
Joined: 1/18/2012
Status: offline
quote:

ORIGINAL: MrRodgers
quote:

ORIGINAL: DesideriScuri
Why should Corporations pay taxes on money that isn't brought back to the US? If they make a profit in, say, Laos and use that money outside the US, why should they have to pay US taxes on it?

But that misses the point entirely. Those profits are made here and simply recorded in Ireland at a scam office there. It's called profit shifting. And to the extent the US tax offices are cracking down it, there is the rush now to tax inversion, or corporate inversion, is the practice of relocating a corporation's legal domicile to a lower-tax nation, or tax haven, usually while retaining its material operations in its higher-tax country of origin.
There are bldgs, in Ireland and the Caymans that are a few floors with a few offices where several hundred companies list offices but have no personnel while having a RA or registered agent hired to facilitate the scam and only for tax avoidance.
Furthermore, if taxes paid in Ireland are written off in the US, that amounts to a US tax code subsidy to Ireland. So the US taxpayer is hurt twice. If they don't want to get twice, the bring the profits home. What has always been needed and may be happening finally, is for the G20 to get together and construct an even playing field for all corp. taxes.


International corporations, regardless of where their HQ's are, pay taxes on the profits in the country they earn them. If the profits from overseas sales never reaches the US, why should a Corporation pay taxes on those profits?

I don't approve of shell game "loans" from the US to foreign locations. That's nothing but a tax scam. But, that's not even what Apple is having to pay on.


_____________________________

What I support:

  • A Conservative interpretation of the US Constitution
  • Personal Responsibility
  • Help for the truly needy
  • Limited Government
  • Consumption Tax (non-profit charities and food exempt)

(in reply to MrRodgers)
Profile   Post #: 19
RE: Tax havens could be on the way out - 9/13/2016 5:25:22 PM   
tj444


Posts: 7574
Joined: 3/7/2010
Status: offline
quote:

ORIGINAL: DesideriScuri

quote:

ORIGINAL: tj444
quote:

ORIGINAL: DesideriScuri
Why should Corporations pay taxes on money that isn't brought back to the US? If they make a profit in, say, Laos and use that money outside the US, why should they have to pay US taxes on it?

cuz every American ex-pat must file tax returns with the IRS and pay taxes on their non-US income (if over a certain amount) so why should big US corps get a free pass when Americans dont? as it is, they already get a free pass since they arent taxed like you would be, they can keep their profit offshore and tax-free from the IRS, while you would still be taxed no matter where you kept your income..


It's telling that your response to an "unfair" situation, is not to end the expat tax, but to impose it on corporations, too.



excuse me??? "it's telling"??? wtf?? The way ex-pat Americans have been treated tax-wise was decided way back when y'all became a country (or there in about).. you are the only developed country in the world that taxes based on residence and citizenship.. I never brought up an end to expat tax cuz I dont ever see that happening.. I think expat Americans & accidental Americans (anyone born elsewhere in the world with an American parent) get a really fucking raw deal, I think its wrong but those people have a very small voice and their only choice to avoid filing & paying US tax is to pay to renounce their American citizenship.. Seriously, are you and the other 300+ million Americans gonna give a shite about them and demand your govt end that? of course not, no one says squat about them and all the new US laws and hoops they must jump thru.. For you to tell me "its telling" that I didnt bring it up, when the fuck have you brought it up to your politicians & govt??

And, if the US were to tax the corporations just like the ex-pats are, there would be a considerable tax windfall that could do some enormous good for your country (assuming it was wisely spent).. but imo the secret deal making with the IRS I spoke about in a previous post in this thread should definately end, those big corporations are screwing honest, hardworking taxpayers and ripping off your country.. when are you (& your fellow Americans) going to speak out to your politicians about that???

< Message edited by tj444 -- 9/13/2016 5:27:55 PM >


_____________________________

As Anderson Cooper said “If he (Trump) took a dump on his desk, you would defend it”

(in reply to DesideriScuri)
Profile   Post #: 20
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