Originally Posted by Guest

Will companies spend tax savings to create jobs? - Dec. 19, 2017

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CEOs agree: Corporate tax cuts won't trickle down | TheHill


Attachment 73246

Since conceit is part of the cult of Femo-Fascism, here's a POP QUIZ (re: Tax Bill)

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Originally Posted by dirtbanker

Those days have been over for sometime.

I can tell you that in order to spend the money here in the states, they will have to pay tax on it. To deposit money earned here in the states into a foriegn account, they will have to report it and pay tax on it.
There are several laws on the books to deal with reporting of foreign bank accounts;
Bank Secrecy Act.
FDIC 1010.610 and 1010.620
IRS requires an FBAR by June 30 each year.
The US has a banking agreement with almost every country in the world. The US provides software to those countries (software to root out their tax cheats) in return information of foriegn accounts held by US citizens and companies.


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Hey Don - Right back at you, read about these "real slow":

Bank Secrecy Act
FDIC 1010.610 and 1010.62
FBAR

Those apply to all bank accounts, Corp or individual. The money held by US entities has to be disclosed. Tax paid to a foriegn country will be credited toward money owed for US tax (that is providing that the income was made in a foriegn country. Income made in the US is taxed by US with no foriegn tax credit, regardless of where it is held).

There is another act that came about in 2012 (?). It forced the other countries (like Switzerland and Nevis) to disclose US held accounts. I will find it...

Thanks in advance for the reply.

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2010...FATCA
Foreign Account Tax Compliance Act - Wikipedia

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Originally Posted by Guest

2010...FATCA
Foreign Account Tax Compliance Act - Wikipedia

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Gee...then WHY does Apple have $285 billion squirreled away in other countries that the US CAN'T touch? Why do countless businesses and corporations have $ billions stashed away to KEEP from paying tax?

From your own link...

"The Foreign Account Tax Compliance Act (FATCA) is a 2010 United States federal law requiring all non-U.S. ('foreign') financial institutions (FFIs) to search their records for customers with indicia[clarification needed] of 'U.S.-person' status, such as a U.S. place of birth, and to report the assets and identities of such persons to the U.S. Department of the Treasury.[1] FATCA also requires such persons to self-report their non-U.S. financial assets annually to the Internal Revenue Service (IRS) on form 8938, which is in addition to the older and further redundant requirement to self-report them annually to the Financial Crimes Enforcement Network (FinCEN) on form 114 (also known as 'FBAR').[2] Like U.S. income tax law, FATCA applies to U.S. residents and also to U.S. citizens and green card holders residing in other countries.

WHERE does it say ANYTHING about a business? This is for INDIVIDUALS it is NOT for businesses who are operating overseas.

IF you WERE correct...there wouldn't BE a discussion about this...the IRS would have just fined them in an audit...wouldn't they?

OK Dirt...you win...I guess. A noticed "US person" in the language...and corporations ARE a US person...so I did some digging.

"Internal Revenue Code Section 7701(a)(30) defines a U.S. person as:[3]

a citizen or resident of the United States,
a domestic partnership,
a domestic corporation,
any estate (other than a foreign estate, within the meaning of paragraph (31)), and
any trust if—
a court within the United States is able to exercise primary supervision over the administration of the trust, and
one or more United States persons have the authority to control all substantial decisions of the trust.
Holders of US residence visa Green Card (until cancelled with the Internal Revenue Service) [4]"

There must be loopholes that are allowing them to get around the law. Because they OBVIOUSLY aren't effected by this law. They SHOULD be paying taxes on these profits. It must be a pretty big loophole because so many are getting away with not paying. I didn't think corporations were covered under the law...BECAUSE so many are sitting on piles of cash earned overseas.

You are correct...they should be paying...so why aren't they?

My guess...they set up foreign corporations and they make the profits.

"Apple has created subsidiaries in low-tax places such as Ireland, the Netherlands, Luxembourg and the British Virgin Islands to cut the taxes it pays around the world. According to The New York Times, in the 1980s Apple was among the first tech companies to designate overseas salespeople in high-tax countries in a manner that allowed the company to sell on behalf of low-tax subsidiaries on other continents, sidestepping income taxes. In the late 1980s Apple was a pioneer of an accounting technique known as the "Double Irish with a Dutch sandwich," which reduces taxes by routing profits through Irish subsidiaries and the Netherlands and then to the Caribbean."

Originally Posted by Guest

AT&T Announces Thousands of Layoffs, Firings Just in Time for Christmas

Well that seems like a piece of coal.

Originally Posted by Don Baldwin

OK Dirt...you win...I guess. A noticed "US person" in the language...and corporations ARE a US person...so I did some digging.

"Internal Revenue Code Section 7701(a)(30) defines a U.S. person as:[3]

a citizen or resident of the United States,
a domestic partnership,
a domestic corporation,
any estate (other than a foreign estate, within the meaning of paragraph (31)), and
any trust if—
a court within the United States is able to exercise primary supervision over the administration of the trust, and
one or more United States persons have the authority to control all substantial decisions of the trust.
Holders of US residence visa Green Card (until cancelled with the Internal Revenue Service) [4]"

There must be loopholes that are allowing them to get around the law. Because they OBVIOUSLY aren't effected by this law. They SHOULD be paying taxes on these profits. It must be a pretty big loophole because so many are getting away with not paying. I didn't think corporations were covered under the law...BECAUSE so many are sitting on piles of cash earned overseas.

You are correct...they should be paying...so why aren't they?

My guess...they set up foreign corporations and they make the profits.

"Apple has created subsidiaries in low-tax places such as Ireland, the Netherlands, Luxembourg and the British Virgin Islands to cut the taxes it pays around the world. According to The New York Times, in the 1980s Apple was among the first tech companies to designate overseas salespeople in high-tax countries in a manner that allowed the company to sell on behalf of low-tax subsidiaries on other continents, sidestepping income taxes. In the late 1980s Apple was a pioneer of an accounting technique known as the "Double Irish with a Dutch sandwich," which reduces taxes by routing profits through Irish subsidiaries and the Netherlands and then to the Caribbean."

"I guess"? Thanks for admitting it.

They can defer taxation, but they still have to declare yearly and they are going to be taxed on those declared yearly earnings eventually.

My company did not do business in other countries, and I have not taken the time to read up on it, so I can't say I understand the provision deferment in the tax code. I can only assume the intent was to allow the other country's taxation to take place prior to the balance being paid to the US?



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Originally Posted by Guest

"I guess"? Thanks for admitting it.

They can defer taxation, but they still have to declare yearly and they are going to be taxed on those declared yearly earnings eventually.

My company did not do business in other countries, and I have not taken the time to read up on it, so I can't say I understand the provision deferment in the tax code. I can only assume the intent was to allow the other country's taxation to take place prior to the balance being paid to the US?



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"I guess" is because Apple IS doing it...they have $285 billion that hasn't been taxed.

You ARE right in what the "law" says...I had assumed that it applies to ONLY individuals...but a LOT of people are interpreting it...or APPLYING it differently.

Thanks for keeping me honest. Better to find out...then go on wrong.

We were both right. And wrong. Every entity gets taxed...but for some...it's not until it's brought back home.

Comcast fired 500 despite claiming tax cut would create thousands of jobs | Ars Technica

Originally Posted by Guest

It doesn't matter if it's held offshore, it still has to be reported...

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You confused me on this one. One of the reasons to do this tax cut was because companies were holding profits offshore. With the tax cut, they should be bringing them onshore for taxation.

COPUFF

Originally Posted by Copuff

You confused me on this one. One of the reasons to do this tax cut was because companies were holding profits offshore. With the tax cut, they should be bringing them onshore for taxation.

COPUFF

I am fairly certain it was explained;

The current tax code allows them to defer taxation. The current tax code requires them to report the accounts and holdings yearly.




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If the New tax code results in less tax on those defered holdings, they would be wise to bring the holdings back here, as the US dollar is more stable than foriegn currency?

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Originally Posted by Guest

If the New tax code results in less tax on those defered holdings, they would be wise to bring the holdings back here, as the US dollar is more stable than foriegn currency?

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Given the chaos in the white house, I think it is erroneous to assume the US dollar is more stable than foreign currencies.I've read that the Canadian dollar, Australian and New Zealand dollars are more stable than the US dollar for example. Of course it would depend on which countries the deferred holdings are located in.

Originally Posted by Guest

If the New tax code results in less tax on those defered holdings, they would be wise to bring the holdings back here, as the US dollar is more stable than foriegn currency?

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Why? Why get taxed at all? Apple has $180 billion overseas it's bought US treasuries with. It's already helping the government. Besides, the costs and profits were all born overseas...so why should the US get a big cut anyway?

More stable today...what about tomorrow?

Originally Posted by Guest

Given the chaos in the white house, I think it is erroneous to assume the US dollar is more stable than foreign currencies.I've read that the Canadian dollar, Australian and New Zealand dollars are more stable than the US dollar for example. Of course it would depend on which countries the deferred holdings are located in.

Apple bought a LOT of US treasuries with that money. Safe for now.

U.S. Employers added 148,000 jobs in December.. Unemployment rate at 4.1%..

Anyone getting laid off right now is having no problem finding another job.