With $160 Billion Merger, Pfizer Moves To Ireland and Dodges Taxes

[ElNono]

With $160 Billion Merger, Pfizer Moves To Ireland and Dodges Taxes

In a $160 billion dollar acquisition, drug company Allergan, a small company based in Ireland, "purchased" Pfizer (http://arstechnica.com/science/2015/11/with-160-billion-merger-pfizer-moves-to-ireland-and-dodges-taxes/), allowing the drug producing giant to move to Ireland and lower its tax rate from about 25 percent to 17-18 percent. Ars reports: "Such inversions, which are said to cost the American government billions in lost tax revenue, have drawn scorn from the Obama Administration and the Treasury Department. Last year, President Obama referred to the deals as 'unpatriotic' loopholes and proposed to close them. And last week, the Treasury announced new rules to make such deals more difficult. But Pfizer’s reverse-inversion skirts the rules, in part by keeping ownership split somewhat evenly between the two companies. After the deal is complete, current shareholders of Allergan, which has the majority of its operations in the US, will own 44 percent of the mega company. The remaining 56 percent will be owned by current Pfizer shareholders."

[boutons_deux]

BigCorp, fucking America, the environment, and Americans at every turn.

[Quetzal-X]

Trump will take care of this shit once and for all!

[Bender]

:cry Why don't companies stay here and pay higher taxes? :cry

[ddjeffries]

I forgot its our "patriotic" duty to pay taxes. If its legal, I'm fine with it. Otherwise, simplify the tax code and close the loopholes.

[Wild Cobra]

Like I keep saying.

We should move from a production based tax system to a consumption based tax. Such BS wouldn't be happening.

[Th'Pusher]

Like I keep saying.

We should move from a production based tax system to a consumption based tax. Such BS wouldn't be happening.

And how would that work for Pfizer? They would be taxed solely on the cost of goods sold?

[ddjeffries]

Like I keep saying.

We should move from a production based tax system to a consumption based tax. Such BS wouldn't be happening.

Sounds like the FairTax. I'd be good with that. The rich would pay more since they spend more. Plus it encourages saving money for those in poverty.

[ElNono]

If you're really poor, you don't have enough money to make ends meet, much less "saving"... not to mention that if they're paying with foodstamps, WIC, etc they're not really paying the tax...

As far as the rich, they can simply purchase anything really expensive as a business expense and take depreciation deductions to make up the difference.

That's why regressive taxes like that really hurt the poor much more than they do the rich.

[ElNono]

That's not to say that a simplified tax code isn't a good idea. That's something that should definitely happen.

[Aztecfan03]

Sounds like the FairTax. I'd be good with that. The rich would pay more since they spend more. Plus it encourages saving money for those in poverty.
isn't sales tax a consumption-based tax? rich people pay a lot lower percentage of their income on sales tax than poor people do since poor people have to spend all of their money.

[baseline bum]

isn't sales tax a consumption-based tax? rich people pay a lot lower percentage of their income on sales tax than poor people do since poor people have to spend all of their money.

I don't understand how a consumption tax is supposed to get the middle and lower classes to start consuming again.

[ElNono]

I don't understand how a consumption tax is supposed to get the middle and lower classes to start consuming again.

why do you hate america?

[baseline bum]

why do you hate america?

because teh gheys can marry

[Spurminator]

How about a "sending-your-company-and/or-jobs-overseas-so-you-can-avoid-taxes" tax?

[Nbadan]

How about a "sending-your-company-and/or-jobs-overseas-so-you-can-avoid-taxes" tax?

That would be too easy....

[angrydude]

If you're really poor, you don't have enough money to make ends meet, much less "saving"... not to mention that if they're paying with foodstamps, WIC, etc they're not really paying the tax...

As far as the rich, they can simply purchase anything really expensive as a business expense and take depreciation deductions to make up the difference.

That's why regressive taxes like that really hurt the poor much more than they do the rich.

Except there wouldn't be business deductions.

And with the fairtax the government would put every single american on the dole up to 40k.

But don't let the facts faze you.

And I don't even think the fairtax is a good idea. Just lower taxes. Everything else still funds the empire.

[angrydude]

And the poor and middle class are never going to start spending again until the banks stop stealing their money (purchasing power). Good luck with that.

[ElNono]

Except there wouldn't be business deductions.

And with the fairtax the government would put every single american on the dole up to 40k.

But don't let the facts faze you.

And I don't even think the fairtax is a good idea. Just lower taxes. Everything else still funds the empire.

There's a dozen "fair tax" proposals out there. None of the ones I've seen eliminate deductions for business expenses. All I've seen is getting rid of personal deductions, AFAIK.

And count me amongst the skeptics when it comes to implementing a tax code with no loopholes for the rich and well connected. Especially after Citizen's United, etc...

[ddjeffries]

I don't understand how a consumption tax is supposed to get the middle and lower classes to start consuming again.

Consuming things is fine. Spending on things that can't be afford while taking out loans is not. A straight consumption tax would encourage savings, one would hope. But people would have more to spend in the first place as all other taxes could be cut. There is no perfect answer unfortunately.

[ddjeffries]

isn't sales tax a consumption-based tax? rich people pay a lot lower percentage of their income on sales tax than poor people do since poor people have to spend all of their money.

It would be a straight consumption tax with no variable rates. all classes would pay the same sales tax rate. Rich would pay more as they buy more expensive stuff in greater quantity. The poor would pay less as they should be buying less expensive items and lower quanitities. People would have more to spend with other taxes thrown out the window.

[boutons_deux]

It would be a straight consumption tax with no variable rates. all classes would pay the same sales tax rate. Rich would pay more as they buy more expensive stuff in greater quantity. The poor would pay less as they should be buying less expensive items and lower quanitities. People would have more to spend with other taxes thrown out the window.

iow, you're full of shit.

[ddjeffries]

iow, you're full of shit.

Read the book.

[boutons_deux]

Read the book.

the US tax code is egregiously rigged by BigCorp, BigFinance, 1% to enrich themselves. Their whores in Congress will block any dramatic changes that don't enrich themselves further.

[boutons_deux]

Global Tax Dodging Just One Part of Pfizer’s Corrupt Business Model (http://www.nakedcapitalism.com/2015/12/global-tax-dodging-just-one-part-of-pfizers-corrupt-business-model.html)

There’s plenty that doesn’t add up about Pfizer’s claim that the low Irish tax rates it will pay by merging with Allergan are necessary if the company is to fund drug research to stay competitive. Consider that while the pharmaceutical giant was provisioning $2.2 billion for income taxes over the first nine months of this year, it was distributing five times as much – $11.4 billion – to its shareholders, $6.2 billion in stock buybacks and $5.2 billion in dividends. That was 159 percent of its profits over these three quarters.

And for Pfizer such mind-numbing distributions to shareholders are nothing new. The company has been piling stock buybacks on top of dividends since 1985. From January 2001 through September 2015, Pfizer paid out $95.5 billion in buybacks and $87.1 billion in dividends, representing 117 percent of its net income.

Meanwhile, it booked $37.1 billion in corporate income taxes to the IRS.

Yet in a Wall Street Journal interview (http://www.wsj.com/articles/pfizer-allergan-considering-combining-1446079506) in October, to forestall the public criticism of corporate flight that was bound to come with the upcoming Pfizer-Allergan merger announcement, Pfizer CEO Ian C. Read moaned that its U.S. tax bill puts the company at a “tremendous disadvantage” in global competition. “We’re fighting,” Read said in the interview, “with one hand tied behind our back.”

When one looks at Pfizer’s gargantuan distributions to shareholders, however, it is obvious that if Read can’t make use of both hands to secure innovation finance, it is not Uncle Sam who tied the knot.

Let’s look at how Pfizer generates the profits that support its mega-distributions to shareholders and its stock-price performance.

Over the past 15 years, Pfizer’s growth has been driven by three major acquisitions: Warner-Lambert in 2000, Pharmacia in 2003, and Wyeth in 2009, each one bringing with it a number of blockbuster drugs. The most lucrative by far has been Lipitor – already a huge blockbuster at Warner-Lambert when Pfizer acquired that company in 2000 – ringing up an annual average of $11.0 billion in sales from 2000 through 2011. But the Lipitor patent expired in 2010, and by 2014 its revenues had fallen to $2.1 billion, although it was still the fifth-best seller among Pfizer’s products.

Pfizer is on the prowl for new blockbusters to fund its buyback habit. In 2014 AstraZeneca, the British-Swedish drug maker with strong sales in cancer drugs, rebuffed (http://www.ft.com/intl/cms/s/0/b69c8a70-1bab-11e4-adc7-00144feabdc0.html#axzz3sz4yHbyE) Pfizer’s takeover attempt. Now Pfizer has struck gold with Allergan, which owns the mega-seller Botox.


With Read as CEO, R&D spending has declined compared with the previous 15 years.

Whatever its recorded R&D spending, however, Pfizer has long since lost the capability to generate its own drug products. Since 2001 the company has launched only four internally developed products, the last one in 2005. In 2010 sales of these four products totaled $3.7 billion, but, in part because of expiration of patents on two of the drugs, by 2014 these revenues had slumped to $1.3 billion.

, Pfizer, along with many other U.S. pharmaceutical companies, has been aggressively jacking up drug prices (http://www.forbes.com/sites/matthewherper/2015/10/13/why-viagra-keeps-going-up-pfizers-ceo-on-the-drug-pricing-controversy/) even more,

Yet whenever Congress has questioned the high prices, major U.S. drug companies say that they need the hefty profit margins to fund more R&D expenditures. For Pfizer, that argument may have held some water back in the ’80s.

But for the past three decades Pfizer has been using its profits to enrich shareholders. U.S. taxpayers pay extortionate prices for indispensible pharmaceutical drugs so that companies like Pfizer, Merck, and J&J can do billions of dollars in buybacks every year to manipulate their companies’ stock prices. And top executives get paid many millions for this financial engineering.

It gets worse. As the drug companies hold U.S. households hostage in our need to consume their products, taxpayers hand over massive amounts of hard-earned pay to support the drug companies’ R&D efforts.

From 1938 through 2014, the National Institutes of Health (NIH) spent a total of $927 billion in 2014 dollars on life sciences research, and this year the NIH budget (http://www.nih.gov/about-nih/what-we-do/budget) is over $30 billion— funded by taxpayers. Drug companies benefit from all sorts of other protections and subsidies, including those under the Orphan Drug Act (http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2257932) of 1983. In Pfizer’s case, Lipitor, its most profitable drug to date, and Botox, its new shareholder-value enhancing therapy, both originated as orphan drugs

Since 2010, Pfizer’s annual sales have plunged by about $20 billion and its employment by more than 40,000 people. But Pfizer’s Read-era profit margins are at a record high for the company while Pfizer’s stock price has soared. If increasing its stock price is Pfizer’s raison d’être, then the allocation of more than 100 percent of profits to “enhancing shareholder value” through buybacks and dividends has worked – but at a huge cost (http://www.brookings.edu/research/papers/2015/04/17-stock-buybacks-lazonick) to American innovation, employment, and income distribution.


http://www.nakedcapitalism.com/2015/12/global-tax-dodging-just-one-part-of-pfizers-corrupt-business-model.html?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+NakedCapitalism+%28naked+capi talism%29

[boutons_deux]

A Tidal Wave of Corporate Migrants Seeking (Tax) Shelter

In the fall of 2008, with General Motors and Chrysler on the precipice of bankruptcy, executives at the car parts supplier Johnson Controls (http://topics.nytimes.com/top/news/business/companies/johnson_controls_inc/index.html?inline=nyt-org) flew to Washington. The company’s president testified before a Senate panel and implored the lawmakers to bail out the auto industry.

“Speaking for our company, and, I am sure for all auto parts suppliers, we respectfully urge the members of this committee, and the Congress as a whole, to provide the financial support the automakers need at this critical time,” Keith Wandell, then the president of Johnson Controls, said, warning that the failure of even one automobile company would “implode” the supply chain and lead to broad job losses.

Congress approved a bailout plan worth almost $80 billion for General Motors and Chrysler, saving the automakers and suppliers like Johnson Controls. By 2010, with its business back on track, Johnson Controls doubled the pay of Stephen Roell, then its chief executive, to more than $15 million.

Despite the federal government’s rescue — and hundreds of millions of dollars in tax breaks over the last several decades from states like Michigan and Wisconsin — Johnson Controls said on Monday it was renouncing its United States corporate citizenship by selling itself to Tyco International, based in Ireland, a deal struck in large part to reduce its tax bill, which it said should drop by about $150 million annually.

Monday’s announcement by Johnson Controls is just the latest effort by corporate America to flee the United States. In the last year, Pfizer (http://topics.nytimes.com/top/news/business/companies/pfizer_inc/index.html?inline=nyt-org) said it was leaving for Ireland, as did Medtronic (http://topics.nytimes.com/top/news/business/companies/medtronic_inc/index.html?inline=nyt-org), the medical device maker. Coca-Cola (http://topics.nytimes.com/top/news/business/companies/coca_cola_company/index.html?inline=nyt-org)’s largest bottling company, after selling its domestic operations, is heading to Britain. (The company, Coca-Cola Enterprises, insists it isn’t for tax reasons.)

Until Washington lawmakers reform the tax code, we will continue to see an exodus of American companies from our shores in search of a lower tax rate. By my count, based on a series of conversations with investment bankers, there are probably at least another dozen deals of meaningful size being negotiated in the pipeline. (Whether those deals will get to the point of a formal announcement, of course, remains unclear.)

The question is what it will take for Congress to not only take notice, but to pass legislation to thwart this steady corporate migration.

http://www.nytimes.com/2016/01/26/business/dealbook/a-tidal-wave-of-corporate-migrants-seeking-tax-shelter.html?partner=rss&emc=rss

Repugs will block any legislation that stops inversions. Repugs LIVE to fuck up govt.

[boutons_deux]

Two Ranking Democrats to Offer Bill Aimed at Inversions

Two House Democrats plan to introduce a bill on Tuesday that would seek to curtail a strategy used by former American companies to cut their United States tax bills.

The measure takes aim at so-called corporate inversions, where American companies move their headquarters overseas through a merger to save on taxes at home. The biggest such deal is Pfizer’s planned $150 billion merger (http://www.nytimes.com/2015/11/23/business/dealbook/pfizer-and-allergan-reach-150-billion-merger-deal.html)with Allergan.

The bill would limit certain tax deductions, blocking a company’s ability to use interest from debt payments by its American operations to its foreign parent company to offset taxes, a practice referred to as “earnings stripping.” The bill will be introduced by Representative Sander M. Levin of Michigan, the ranking Democrat on the Ways and Means Committee, and Representative Chris Van Hollen of Maryland, the top Democrat on the Budget Committee.

The Democrats are also taking aim at Republican lawmakers after several attempts to get legislation through Congress in the last few years.

http://www.nytimes.com/2016/02/23/business/dealbook/two-ranking-democrats-to-offer-bill-aimed-at-inversions.html?partner=rss&emc=rss

Repugs will block this bill, because for Repugs, tax avoidance, tax evasion are patriotic.

[Winehole23]

U.S. drugmaker Pfizer Inc and Ireland-based Allergan Plc formally announced the scrapping of their $160 billion merger on Wednesday, in a big win for President Barack Obama who has been pushing to curb tax-slashing “inversion” deals.

The announcement followed the unveiling of new U.S. Treasury rules on Monday aimed at curbing such deals. The merger would have allowed New York-based Pfizer to cut its tax bill by redomiciling to Ireland, where tax rates are lower.


A source familiar with the matter told Reuters on Tuesday that the deal would be terminated.


Pfizer said on Wednesday it would pay Allergan $150 million as reimbursement of expenses related to the deal.

via Reuters

[Winehole23]

One reason the Administration could act is that countries in advanced economies are coming to the point of view that corporate tax minimization has gone to far. Admittedly, the austerian policies of the Eurozone are no doubt a big driver: countries that are budget-starved and squeezing their own citizens can’t afford to let big corporations be the equivalent of tax scofflaws, even if their moves are kosher under the current tax codes. From a European Commission press release this January (http://europa.eu/rapid/press-release_MEMO-16-160_en.htm):


Why has the Commission made the fight against corporate tax avoidance a priority?

Corporate tax avoidance deprives public budgets of billions of euros a year[1], creates a heavier tax burden for citizens and causes competitive distortions for businesses that pay their share. It also undermines the EU goals of growth, competitiveness and a stronger Single Market. The cross-border nature of corporate tax avoidance means that action only at the national level cannot tackle the problem and can even lead to further problems. Unilateral efforts by Member States to protect their tax bases create administrative burdens for businesses, legal uncertainty for investors and new loopholes for tax avoiders to exploit.

Therefore, the Commission is pursuing an ambitious campaign for a coordinated EU approach against tax avoidance, following the global standards developed by the OECD last autumn, to boost Member States’ collective stance against this problem, restore fairness in corporate taxation and ensure stability for businesses and investors in the EU.


Even though any multi-country initiative takes time, my tax mavens tell me the Europeans are serious. And the unusually firm tone of the official statement seems consistent. For instance, “Member States adopted the Commission’s proposal for transparency on tax rulings in record time and other important corporate tax reforms have been launched.”


The Wall Street Journal gave a high-level summary of the main effects of the changes. Mind you, it’s 300 pages of new rules, so I sincerely doubt anyone has analyzed this in depth:


How do they do that?

First, they go after what they call “serial inverters,” companies that have engaged in multiple inversion transactions. The rules would disregard three years of past mergers with U.S. corporations in determining the size of the foreign company. By subtracting the value of U.S. assets a foreign company had acquired, the foreign company would become smaller in relation to the U.S. company.

Why does that size matter?

After a merger, if the shareholders of the former U.S. company own at least 80% of the combined firm, the government treats the new combined business as subject to U.S. taxes, basically negating the inversion, even if its address is abroad. If they own at least 60%, some restrictions apply but the company is still considered foreign. That’s led companies to keep their inversions below 60%—and prompted the government to propose rules halting various techniques for doing so…

What else is Treasury doing?

The government issued regulations against what’s known as earnings stripping, a kind of transaction that typically occurs after an inversion. Companies can lend money from their foreign headquarters to what is now the U.S. subsidiary in a transaction that has no effect on the consolidated company’s books. But it matters for tax purposes, because the U.S. subsidiary gets interest deductions against the world-high 35% U.S. corporate tax rate, effectively pushing income to a country with a lower tax rate. The rules would give the government more authority to treat those debt transactions as equity movements under the tax code.


A top international tax expert added by e-mail:


The new stuff concerns interest deductions. It is not limited to inversions. Foreign-parented companies have been able to strip out their US income with intragroup interest deductions forever. No one bothered them about it because they hire people for US auto plants.

Now under the new rules, interest payments would not be deductible, and would be treated as dividends, meaning they might incur withholding tax at the border. Taxpayers also have to show that intercompany debt would be repaid.

The rules say which intercompany debt they hit. They think they can differentiate debt that represents real capitalization of a US affiliate from phony debt that involved no new capital coming into US. If it isn’t new capital, the intragroup debt is preferred stock.

You don’t have to have done an inversion to be affected by this rule. You merely need to be paying interest to a foreign parent.


The Financial Times reports that US tax crackdown provokes foreign fur (http://www.ft.com/intl/cms/s/0/59fef9e8-fb50-11e5-8e04-8600cef2ca75.html)y. From the story:


The angry rhetoric came a day after the Treasury department released new proposals which threatened the biggest planned inversion to date — Pfizer’s takeover of Irish-domiciled Allergan — and triggered big losses for some hedge funds, such as Paulson & Co and Third Point.

“It came as a total surprise. Everyone thought the Treasury had used all their firepower,” said one hedge fund manager…

Ms [Nancy] McLernon [president of the Organisation for International Investment, a trade group for foreign companies in the US] said the proposal would penalise foreign companies with long histories in the US that use legitimate intra-company loans to pay for investments in facilities and equipment.

Her group’s members include Nestlé, Royal Dutch Shell, BASF, Airbus, Nissan, Unilever, Deutsche Telekom, Tate & Lyle and other multinationals.


The entertaining part was that the generally business friendly FT comments section for the most part wasn’t buying it. Some reactions:


Nestle tax executive: jog on. Your cost of capital is lower than a snails belly and the US market is too big – you need it more than it needs you. Go play your games somewhere else.
Judging by the shrill response, The President has hit the target, and how! Excellent Mr President! Carry on!

US subsidiaries of foreign multi-nationals can always borrow from US banks or issue their own bonds instead of relying on intra-company loans.

All of those American politicians that businesses have bought over the years, did not stay bought. Who knew?


It’s important to note that Treasury took these moves took the form of new administrative guidance, which is roughly equivalent to a new reading of existing laws. Professor Victor Fleischer, in an initial reading at the New York Times (http://www.nytimes.com/2016/04/06/business/dealbook/on-inversions-the-treasury-department-drops-the-gloves.html), points out that the Treasury position on stepped transactions and its use of a 50 year old but largely dormant rule allowing Treasury to decide what is debt versus equity for tax purposes is defensible but might be challenged successfully in court. The Economic Policy Institute praised Treasury for doing the best it could within its constraints:


The Treasury’s regulatory actions continue to provide temporary fixes, which will help reduce the short-term erosion of the U.S. corporate tax base. They deserve credit for using the limited tools available to them in the most robust way to slow this erosion. But regulatory authority can only go so far, and legislative action is necessary to fully stop this type of corporate tax evasion.


http://www.nakedcapitalism.com/2016/04/treasury-implements-new-rules-aimed-at-inversions-other-tax-strategies-scuttling-pfizer-allergan-deal-and-evoking-howls-from-pharma.html

[CosmicCowboy]

From a legal standpoint Pfizer has legitimate grounds to sue for having this merger blocked. Changing the law mid-merger when the merger had been based on existing law is bullshit. Rationally, however, they blew up the merger instead of going to war with the US government...they would probably have never gotten another drug approved if they had fought.

The problem is the US's ridiculously high tax rate...not these corporations being rational and seeking a tax friendlier environment.

[boutons_deux]

"US's ridiculously high tax rate" US corps pay about 11% on average.

Many BigCorps get $100Ms of refunds after $10Bs of profits.

boo hoo hoo

US corporate tax receipts are LOWER than corporate tax receipts in other industrial countries.

[CosmicCowboy]

"US's ridiculously high tax rate" US corps pay about 11% on average.

Many BigCorps get $100Ms of refunds after $10Bs of profits.

boo hoo hoo

US corporate tax receipts are LOWER than corporate tax receipts in other industrial countries.




Suck a dick, Bookaki.

I'm sure Pfizer wanted to move to Ireland to raise it's taxes.

fucking idiot.

[boutons_deux]

Suck a dick, Bookaki.

I'm sure Pfizer wanted to move to Ireland to raise it's taxes.

fucking idiot.

no, Pfizer was moving to cut it's low tax rate even further. Ireland is a low-tax haven, since it's really got nothing else to offer, having been shit on by the English for centuries.

[tlongII]

"US's ridiculously high tax rate" US corps pay about 11% on average.

Many BigCorps get $100Ms of refunds after $10Bs of profits.

boo hoo hoo

US corporate tax receipts are LOWER than corporate tax receipts in other industrial countries.




You lie. That's not unusual though.

http://www.forbes.com/sites/taxanalysts/2015/03/25/the-truth-about-corporate-tax-rates/#b5a47720a54a

[boutons_deux]

You lie. That's not unusual though.

http://www.forbes.com/sites/taxanalysts/2015/03/25/the-truth-about-corporate-tax-rates/#b5a47720a54a

Forbes is Capitalist Tool, lots of other data contradicts it.

[boutons_deux]

7 things you absolutely must know about corporate taxes

http://money.cnn.com/2014/08/14/news/economy/corporate-taxes-inversion/

BigCorp/1% have corrupted enough politicians to reduce their Federal tax payments to just 10% of total Fed receipts, vs 30% in the 1950s.

Guess who gets to make up the difference?

[Winehole23]

 “Big Pharma continues to lobby for laws that not only handicap Medicare from negotiating drug costs, but also continues to hold American consumers captive as prescription drug buyers, legally barring them from purchasing drugs from other countries,” Oskoui explained.


Indeed, Oskoui makes a more controversial point. By allowing US companies to jack up prices here, American consumers are unwittingly subsidizing single-payer healthcare systems in Canada, France, and elsewhere. Americans pay more—a lot more—for drugs so Pfizer and the rest can make “sweetheart deals” on the prices they charge in Europe and still turn a profit. Social democracies, it turns out, are the hard-headed business managers. Uncle Sam is played for a sucker.

http://www.thenation.com/article/capitalist-deserter-pfizer-just-got-a-spanking/

[boutons_deux]

http://www.thenation.com/article/capitalist-deserter-pfizer-just-got-a-spanking/

That's been evident for years, but at least someone finally published it. Just another way Corporate-America fucks Human-Americans with complicity from US govt.

[baseline bum]

Just another shit stain Bush left on this country.

[boutons_deux]

Just another shit stain Bush left on this country.

please don't limit shit stains to dubya. Repugs have been shit staining America since at least, Tricky Dick Nixon, and back to racist Goldwater. And they don't wipe.

[Quetzal-X]

no, Pfizer was moving to cut it's low tax rate even further. Ireland is a low-tax haven, since it's really got nothing else to offer, having been shit on by the English for centuries.


"Ireland...since its really got NOTHING else to offer"--

Thats Right!

Those red motherfuckers would have withered away like dust had they not stolen the potato from the Native American Native Population Peruvians. Imagine the "potato famine" - those fuckers wouldnt even be able to feed themselves had they not benefited from white christian terrorism. Native people "give" those devils the potato and maize and they in return give Micky fuckin D's (diabetes) Fucking takers i tell you. Heathens.

[boutons_deux]

Here's another way BigCorp and capitalists have been outwitting govts.

Denmark Seeks EU Fix To ‘Div-Arb’ Deals

A Danish member of the European Parliament is asking the trading bloc’s executive arm to examine the tax avoidance deals, which are going on in at least 13 member states of the European Union.

A Danish politician is asking the European Commission (http://ec.europa.eu/index_en.htm) to examine stock loan deals that drain the country and many of its neighbors of tens of millions of dollars in forgone tax revenues.

The request (https://www.documentcloud.org/documents/2992672-MEP-Jeppe-Kofod-Systematisk-Udl%C3%A5N-Af-Aktier-for.html), made by Jeppe Kofod (http://www.europarl.europa.eu/meps/en/124870/JEPPE_KOFOD_home.html), a Danish member of the European Parliament (http://www.europarl.europa.eu/portal/en), could open a new front in lawmakers’ efforts to stamp out the deals, which help large shareholders avoid paying their share of taxes on dividends paid out by corporations in Denmark and elsewhere.

“I have asked the Commission to examine the extent of the problem - both in relation to Denmark and in general.” Kofod said in an interview. “They also need to look at whether it is legal. If so, we must confront it with regulation.”

The Commission initiates and implements European Union policy across the bloc’s 28 member countries (http://europa.eu/about-eu/countries/index_en.htm), of which at least 13 — including Denmark — are losing revenue to the tax avoidance deals, according to confidential trading records obtained by ProPublica. That count excludes Germany, which passed a law (https://www.propublica.org/article/germany-waves-auf-wiedersehen-to-costly-wall-street-tax-scheme) in June to end the deals there.

In the transactions (https://www.propublica.org/article/a-wall-street-deal-that-turns-taxes-into-profits), known as dividend arbitrage or “div-arb,” banks temporarily transfer large holdings of stock from tax-liable shareholders to investors with lower or no tax obligations.

The transfers, which occur for just a few days around dividend time (https://projects.propublica.org/graphics/dividend), help the shareholders capture a larger share of dividend payments by avoiding taxes.

They split the savings with the banks and tax-free investors who enable the deals.

https://www.propublica.org/article/denmark-seeks-eu-fix-to-div-arb-deals?utm_campaign=sprout&utm_medium=social&utm_source=twitter&utm_content=1468430649 (https://www.propublica.org/article/denmark-seeks-eu-fix-to-div-arb-deals?utm_campaign=sprout&utm_medium=social&utm_source=twitter&utm_content=1468430649)

[boutons_deux]

Obama plan to stop tax inversions stirs U.S. business concerns

The Obama administration's plan to prevent American companies from shifting their headquarters overseas to avoid U.S. taxes is coming under fire from companies and banks that say it would be costly and cumbersome.

At issue are proposed Treasury regulations to combat "earnings stripping," a key goal for companies that carry out tax-avoiding mergers known as "inversions" to reincorporate abroad, if only on paper, to cut their taxes.

The practice effectively shifts taxable earnings from U.S. operations to the redomiciled former American parent as debt interest payments that are tax deductible in the United States and subject to a lower income tax rate overseas.

The Treasury Department is scheduled to hold a public hearing on the proposed changes on Thursday.

The administration's proposals, which could be finalized within months, have already dampened interest in global mergers.

The proposals are backed by Democrats in Congress and academics as a responsible step to prevent corporations from exiting the U.S. tax system. Republicans say the measures overstep administration authority and could discourage foreign investment in the United States.
Businesses and trade groups representing sectors ranging from bankers and retailers to manufacturers and oil producers said a Treasury proposal to end the deductions by reclassifying the debt as equity would disrupt operations and saddle businesses with new red tape.

U.S. multinational Procter & Gamble Co warned Treasury the proposed rules would require countless changes throughout its corporate structure if myriad daily loans between affiliates were recharacterized as equity investments.

"It will be extremely difficult, if not impossible, to monitor and administer," P&G's Chief Financial Officer Jon Moeller told the Internal Revenue Service in a letter before the regulatory comment period ended last week.

He warned that the company would face pre-tax costs of $220 million to $340 million a year as a result of adverse tax consequences and burdens. :lol

http://www.reuters.com/article/us-usa-tax-inversions-idUSKCN0ZT2OE?feedType=RSS&feedName=politicsNews&utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+Reuters%2FPoliticsNews+%28Reu ters+Politics+News%29

Fear and Lies from tax-cheat BigCorp. If their lips are moving ...

"adverse tax consequences and burdens"? meaning: BigCorp would lose one way of evading US taxes.

[boutons_deux]

Tax frauders, evaders Repugs love to screw American for profit. Tax evasion is Repug idea of patriotism

Republicans urge U.S. Treasury to overhaul tax inversion proposals


Republican lawmakers called on U.S. Treasury Secretary Jack Lew on Monday to overhaul proposed regulations intended to crack down on American companies that try to reduce their U.S. taxes by rebasing abroad in a process known as inversion.

In separate letters, top Republicans on the Senate Finance Committee and House Ways and Means Committee warned on Monday that Treasury is moving too quickly to adopt regulations to prevent overseas mergers known as tax inversions, in which U.S. firms relocate their headquarters in countries with lower corporate tax rates.

"If the proposed regulations are not completely overhauled, they would

damage our economy, :lol

increase the barriers to investment for American businesses and innovators, :lol and

interfere with the growth of ... good-paying jobs," :lol

said a letter to Lew from Ways and Means Committee Chairman Kevin Brady and other Republicans on the panel.

"We cannot allow this to happen,” they wrote.

The regulations were proposed in April and Treasury has indicated that it intends to move swiftly to finalize the rules. Industry leaders fear the rules could be in place permanently as early as September.

One new inversion rule, which has already been imposed on a temporary basis, was challenged this month in federal court by business groups including the U.S. Chamber of Commerce.

http://www.reuters.com/article/us-usa-tax-inversions-idUSKCN10X24F?feedType=RSS&feedName=politicsNews&utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+Reuters%2FPoliticsNews+%28Reu ters+Politics+News%29