And? Your point being?

A most legitimate question indeed.

my "point being"
I was replying to another posting...
"Ireland had a pretty easy time because nobody seems to mind that they are a haven for tax cheats from the USA like Apple."

They were talking about Northern Ireland possibly following, but the "tax cheats" are in Ireland not Northern Ireland. I was simply pointing this out and honestly, I could be wrong but all I ever saw was these tech companies are not part of the UK but rather in Ireland.

What wonderful logic to suggest that corporations that decide locate themselves in nations with favorable tax conditions for their business are somehow "tax-cheats". A classic example of static analysis, assuming that when taxes are levied they will just be paid without consequence in perpetuity. Corporations tend flee oppressive taxes just like people do. The larger point to be considered here is just how absurd the tax rates have to be to get corporations to relocate, which is no small investment. It takes a pretty oppressively high and unreasonable tax rate to drive them away. Tax policy is far more complex than just assuming that corporations are mammoth bodies of evil that deserve to be laden with as many taxes as man can conceive of until they fail. Business are not started with the intention of failing, but to profit. Profit is not evil, and a free market will govern profit. The evil comes in excessive taxation, which in turn ultimately hurts the consumer.

Personally, I'm planning to kill myself as a result of the no vote. I'm just looking for the best way to do it.

Just wanna say that Scotland voted to remain in the union (but the result will probably be discussed)

What mainly goes on in Ireland is not "relocation". Nor is it a low tax rate in Ireland which attracts corporations. Ireland is virtually alone among rich nations in its regulation of a phenomenon called "transfer pricing". This is the accounting treatment of transactions within and between units of large corporations. The pricing of such transactions effectively determine in which country and under what laws and taxes the profits from a corporations activities occur. Every ad sold by Google globally is a transaction between the Google subsidiary in Ireland and the Google subsidiary in the Dutch Antilles. The purpose of the presence in Ireland is not to take advantage of Ireland's low corporate tax rate but to have all of the profits occur under the zero tax regime in the Dutch Antilles. It is also why the majority of American pharmaceuticals are "manufactured" in Ireland. The intellectual property that defines the process is transferred at a negligible cost to the Irish subsidiary and then all profits occur at the "manufacturing" stage. As a kicker, the American division then bears the full R&D costs and can often write down a tax lose. This is why multinational heavy Minnesota has Ireland as its number two trading partner ahead of Mexico and medium sized manufacturer heavy Wisconsin does not list Ireland among its top ten trading partners.

Two of my friends from grad school were recruited into very well paying jobs with consulting companies to help corporations design transfer pricing schemes to minimize their corporate taxes. Such schemes rarely involve actually moving much of anything to Ireland.

I did a little arithmetic during my second year in grad school. If you looked at the three most intellectual property heavy industries (pharmaceuticals, software and IT hardware), Irish workers generates 8 times the value added of similar workers in Germany. And yet Ireland had seen no employment growth in those three industries over the previous ten years while Germany had been adding jobs in those sectors like gang busters.

OECD is slowly rolling out a plan to fight this. Not too much on the details yet, but implementation is scheduled for circa 2016

http://thehill.com/policy/finance/217857-oecd-rolls-out-anti-tax-evasion-measures

"What wonderful logic to suggest that corporations that decide locate themselves in nations with favorable tax conditions for their business are somehow "tax-cheats". "

Even John McCain has called Apple a tax cheat. What else do you call it when you set up subsidiaries in foreign countries solely for the purpose of avoiding taxes? Irish law does not tax corporations that are managed in other countries, and US law cannot tax Apple for units not incorporated in the US.

"The larger point to be considered here is just how absurd the tax rates have to be to get corporations to relocate, which is no small investment."

No, they are not absurd. They are low considering the astronomical profits made and considering barely anybody bothers to pay the tax. Corporations original purpose was to serve a public function. Corporations have long simply been in it for themselves. They don't care about their countries, their communities. Whatever happened to economic patriotism? It doesn't exist. These people are just greedy.

It's called tax planning and if you're going to place blame it should be on the governments like the US which allow companies to get away with these schemes.

Has anybody seen the 2003 documentary "The Corporation" ?

http://www.amazon.com/Corporation-Milton-Friedman/dp/B0007DBJM8/ref=sr_1_1?s=movies-tv&ie=UTF8&qid=1411163342&sr=1-1&keywords=the+corporation+movie

That movie, which I encourage everybody to watch at least once, clearly shows why corporations act like typical psychopaths.

Indeed, if you check the Personality Diagnosis Checklist of the World Health Organization, you can go through the characteristics of some mental disorders one by one and you will see that these apply to corporations :

- Callous unconcern for the feelings of others.
- Incapacity to maintain enduring relationships.
- Reckless disregard for the safety of others.
- Deceitfulness : repeated lying and conning others for profit.
- Incapacity to experience guilt.
- Failure to conform to social norms with respect to lawful behaviours.

→ These combined parameters define a typical psychopath.

That comment is not mine. It is made in the movie by Robert D. Hare, who is a specialist in the study of criminal psychology :

https://en.wikipedia.org/wiki/Robert_D._Hare

"the governments like the US which allow companies to get away with these schemes."

Primary responsibility lies with those committing the act. Just because something is allowed doesn't mean you have to do it.

Well, I wouldn't waste time trying to guilt corporations into paying. They're playing a game, plain and simple, and if one does it everyone else will try. Same with individuals; it's competitive behaviour, which has its place as long as the rules of the game aren't terrible. I commend the government efforts to close the loopholes. It's been a long time coming, and of course it takes economic suffering to put focus on it. Especially economic suffering contrasting with record corporate and financial profits.

Only some of the corporations do so. Some, like IKEA, I believe, go to great lengths to develop long term relationships with their suppliers.. But I feel like IKEA is more the exception than a rule.

Hopefully the governments of the world will get their act together and close the loopholes. If the OECD implements it, then that'll pretty much stop the practice.

I wouldn't use IKEA as an example of good behaviour when we're talking about taxes... They play a very complex shell game that basically gets them classified as a charity. It's not even entirely clear who *really* owns IKEA. They play the tax dodge even more eloquently than mere Irish transfer copycats.

The special position of Ireland is precisely that they have declined to sign on to any of the EU or OECD agreements of cooperation regarding transfer pricing.

I am not sure what "even John McCain" has to do with anything.

Technically, every municipal government in the US is a corporation. If we mean to limit the definition to contractual arrangements between people characterized by limited liability, then I have a tough time with anyone saying X is the "original function" of corporations as such things practically predate true states.

Also governments create "the loopholes" on purpose. It is how both real corruption happens and represents "stealth spending" and "stealth regulation" which may well dwarf what exists above board. Most countries could easily adopt very simple tax systems without much room for shenanigans and yet they do not. Presumably, legislative politicians are making these decisions on some rational basis. To claim that it is purely corruption is the simplification of a child. A simple tax system would close off the ability of politicians to exercise personal power in many of the ways that they are used to doing so. That they choose to maintain the system at the cost of corporations playing these sorts of games is not terribly surprising.

Attempting to apply psychological pathologies of individuals to collections of people is intellectually vacuous. There are a whole mess of conditions and assumptions that have to be maintained to aggregate "rational" individuals into a collective such that the rules of "rational" behavior are not violated. Also, corporations are generally much better behaved than proprietorships. Referencing Agitprop filmmakers is really not appropriate if you wish to be taken seriously.

Ireland has indicated that they would sign the OECD plan, I think.

But yeah,I have no idea about IKEA (privately owned, founder is pretty well known) and their tax evasion. I just heard someone mention that companies don't develop long term relationships with suppliers and they're a good example as to why that's not true

Limited liability was a later development to corporate law and is not in any way intrinsic to a corporation. The original corporations were entities given royal charter for a specified purpose and the charter could be revoked at any time. The early American corporations were severely restricted as to what they could do, and states could revoke their charters. For example, the Supreme Court of Virginia stated in 1809 that if an applicant for a corporate charter’s “object is merely private or selfish; if it is detrimental to, or not promotive of, the public good, they have no adequate claim upon the legislature for the privileges.”

http://books.google.com/books?id=S2M2AQAAMAAJ&pg=PA521&lpg=PA521&dq=object+is+merely+private+or+selfish;+if+it+is+detrimental+to,+or+not+promotive+of,+the+public+good,+they+have+no+adequate+claim+upon+the+legislature+for+the+privileges&source=bl&ots=KguHdkQrXW&sig=LaZOunn3n8ELOfGYU-zXrTWlGaw&hl=en&sa=X&ei=wfccVK-lB4aqyASFxIGACw&ved=0CCYQ6AEwAQ#v=onepage&q=object%20is%20merely%20private%20or%20selfish%3B%20if%20it%20is%20detrimental%20to%2C%20or%20not%20promotive%20of%2C%20the%20public%20good%2C%20they%20have%20no%20adequate%20claim%20upon%20the%20legislature%20for%20the%20privileges&f=false

"I am not sure what "even John McCain" has to do with anything."

The point is that even rightwing, pro-business Senators claim Apple is a tax cheat. Even the US business press does. To say otherwise is to put your position well outside the mainstream of even the ranks of conservative opinion holders.

"A simple tax system would close off the ability of politicians to exercise personal power in many of the ways that they are used to doing so."

Simple tax systems are easier to evade. A daunting array of complicated taxes makes it much harder for people to evade all of them. It would also close off a lot of popular incentive programs that middle class homeowners and such, are very attached to. Which is why Mitt Romney never specified which loopholes he would close during the 2012 race, since all of them were popular with the broad public.
Complaining about tax loopholes is a lot like complaining about earmarks. Everybody hates the general concept in theory but supports the specific examples.

"Attempting to apply psychological pathologies of individuals to collections of people is intellectually vacuous. There are a whole mess of conditions and assumptions that have to be maintained to aggregate "rational" individuals into a collective such that the rules of "rational" behavior are not violated."

Not really. Collectivities often have a unified culture, training programs, way of thinking, and process of decision-making that makes such aggregations pretty easy.

"Also, corporations are generally much better behaved than proprietorships."

I don't know where this statement comes from or how it's relevant. Do proprietorships have the same access to capital and influence that corporations do?

"Referencing Agitprop filmmakers is really not appropriate if you wish to be taken seriously."

Using the term McCarthyite term Agitprop, especially for film, is not something you want to use if you wish to be taken seriously.

Limited liability agreements date back millenia if one looks outside Anglophone common law tradition.

Wait, John McCain is "rightwing"? I'm not even sure what "pro-business" means in the context that you use it.

Am I a person? Would not my being a person make me a necessary member of the collective "Everybody"? Do you proclaim that I agree with your assertion? It would seem to me that either you must be publicly claiming that I agree with something I just disagreed with or else be denying me "person-hood"....well, that or you are the kind of intellectually lazy person prone to vacuous universal statements as a point of rhetoric. I do in point of fact know some of the preeminent academic economists on the planet Earth expert in the theory of designing tax structures. If you would really like to get into arguments about simplicity and evade-ability, bring it on.

If you can prove this assertion, there is a Nobel Prize in Economics waiting with your name on it, not to mention presumably an endowed chair in any respectable Sociology Department on Earth.

In terms of basic regulatory rules following this is a pretty standard empirical finding. To offer a simple example, which firm do you suspect has a worse maintenance and clean up record, ExxonMobil or Koch Industries? Who is more likely to try to cheat you out of your damage deposit when you move out of an apartment, a giant REIT or a family landlord? With the small sample size of my friends in the local legal aid, the answer is overwhelming the latter.

Please offer me a single instance of Joseph McCarthy or Roy Cohn or even Bobby Kennedy using the term Agitprop. But kudos for resorting to accusations of McCarthyism. My intellectual respect for grows without bound.

I've never heard of the term Agitprop before now.