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  1. #1
    Pain Strength Happiness ManuBalboa's Avatar
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    http://www.huffingtonpost.com/2011/0..._n_851746.html

    Jokes and jokes and jokes. Meanwhile, Facebook & Google use the "Double Irish" loophole to save billions in tax money. America

    From Wikipedia, the free encyclopedia
    The Double Irish Arrangement is a tax avoidance strategy that U.S. based multinational corporations use to lower their income tax liability. The idea is to use payments between related en ies in a corporate structure to shift income from a higher-tax country to a lower-tax country. It relies on the fact that Irish tax law does not include effective transfer pricing rules.
    Overview

    Typically, the company arranges for the rights to exploit intellectual property outside the United States to be owned by an offshore company. This is achieved by entering into a cost sharing agreement between the U.S. parent and the offshore company, in the terms of U.S. transfer pricing rules. The offshore company continues to receive all of the profits from exploitation of the rights outside the U.S., without paying U.S. tax on the profits unless and until they are remitted to the U.S.
    It is called "The Double Irish" because it requires two Irish companies to complete the structure. The first Irish company is the offshore company which owns the valuable non-U.S. rights. This company is tax resident in a tax haven, such as Bermuda or the Cayman Islands. Irish tax law provides that a company is tax resident where its central management and control is located, not where it is incorporated, so that it is possible for the first Irish company not to be tax resident in Ireland. The first Irish company licenses the rights to a second Irish company, which is tax resident in Ireland, in return for substantial royalties or other fees. The second Irish company receives income from exploitation of the asset in countries outside the U.S., but its taxable profits are low because the royalties or fees paid to the first Irish company are deductible expenses. The remaining profits are taxed at the Irish rate of 12.5%.

    brb ing about corporate greed then receiving campaign money from said corporate greed

  2. #2
    Alleged Michigander ChumpDumper's Avatar
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    How is that cheating?

  3. #3
    keep asking questions George Gervin's Afro's Avatar
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    http://www.huffingtonpost.com/2011/0..._n_851746.html

    Jokes and jokes and jokes. Meanwhile, Facebook & Google use the "Double Irish" loophole to save billions in tax money. America




    brb ing about corporate greed then receiving campaign money from said corporate greed
    so it's legal.... mmmmmk

    so I guess you agree that corporations shouldn't hide their money..welcome to the democrat side of things!

  4. #4
    I play pretty, no? TeyshaBlue's Avatar
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    so it's legal.... mmmmmk

    so I guess you agree that corporations shouldn't hide their money..welcome to the democrat side of things!
    ...where apparently the head Democrat is choosing to turn his head to this?

    And, I think, most companies that do this, do it legally. Ethically? Nope.

  5. #5
    keep asking questions George Gervin's Afro's Avatar
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    ...where apparently the head Democrat is choosing to turn his head to this?

    And, I think, most companies that do this, do it legally. Ethically? Nope.
    If he demonizes them he is attacking the job creators.. it he remainis silent he's allowing this to happen...

    damned if he does..damned if he doesn't


    like you said.. can they do it? Sure.. Should they do it? Probably not..

  6. #6
    I play pretty, no? TeyshaBlue's Avatar
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    If he demonizes them he is attacking the job creators.. it he remainis silent he's allowing this to happen...

    damned if he does..damned if he doesn't
    Sucks to be the POTUS.

  7. #7
    keep asking questions George Gervin's Afro's Avatar
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    Sucks to be the POTUS.
    it is a big boy job!

  8. #8
    Pain Strength Happiness ManuBalboa's Avatar
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    I don't care, get their Irish on - wgaf. Just laughing at the clown president whoring himself out to get the youth vote. GE ing over IRS, but hey - Green Week on Sunday Night Football is the son. The stage is green yo!

  9. #9
    Alleged Michigander ChumpDumper's Avatar
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    Which laws were broken?

  10. #10
    W4A1 143 43CK? Nbadan's Avatar
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    that's just it...no laws were broken....

    ...the entire debt can be solved by closing tax loopholes on corporations, raising taxes to Clinton levels on those making more than $250k and reducing spending on defense by 10-20 percent...

  11. #11
    Pimp Marcus Bryant's Avatar
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    that's just it...no laws were broken....

    ...the entire debt can be solved by closing tax loopholes on corporations, raising taxes to Clinton levels on those making more than $250k and reducing spending on defense by 10-20 percent...
    Bull .

  12. #12
    Veteran Wild Cobra's Avatar
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    that's just it...no laws were broken....

    ...the entire debt can be solved by closing tax loopholes on corporations, raising taxes to Clinton levels on those making more than $250k and reducing spending on defense by 10-20 percent...
    Bull .
    You have to remember. Dan's a card carrying Kool-Aid drinker.

  13. #13
    W4A1 143 43CK? Nbadan's Avatar
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    What part?

  14. #14
    Pimp Marcus Bryant's Avatar
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    You know which.

  15. #15
    W4A1 143 43CK? Nbadan's Avatar
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    No, I don't...

    you think the debt is gonna stay at over a trillion dollars annually forever?

  16. #16
    Veteran Wild Cobra's Avatar
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    No, I don't...

    you think the debt is gonna stay at over a trillion dollars annually forever?
    You need to get tour terms right. Debt and deficit are two different things. You mean deficit, right?

  17. #17
    W4A1 143 43CK? Nbadan's Avatar
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    Are we gonna turn this into another petty argument about semantics

    Here are the facts

    Corporate Taxes as a Percentage of Federal Revenue

    1955 . . . 27.3%
    2010 . . . 8.9%

    Corporate Taxes as a Percentage of GDP
    1955 . . . 4.3%
    2010 . . . 1.3%

    Individual Income/Payrolls as a Percentage of Federal Revenue
    1955 . . . 58.0%
    2010 . . . 81.5%
    Source: Citizens United

    Anyone who is serious about closing the US deficit should consider the changes in what corporations pay in taxes and the rise of the deficit.

  18. #18
    Veteran Wild Cobra's Avatar
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    Are we gonna turn this into another petty argument about semantics

    Here are the facts

    Individual Income/Payrolls as a Percentage of Federal Revenue
    1955 . . . 58.0%
    2010 . . . 81.5%
    Too bad they didn't separate income taxes from payroll taxes.

    As for corporate rates going down, it's called compe ion. As goods can be transported nationally cheaper, and now globally, we are still taxing national producers out of existence in many cases.

    I am all in favor of returning tariffs if we are going to continue taxing production.

  19. #19
    W4A1 143 43CK? Nbadan's Avatar
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    Too bad they didn't separate income taxes from payroll taxes.
    Payroll taxes aren't company money, they are taxes withheld from employee paychecks...

  20. #20
    Veteran Wild Cobra's Avatar
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    Payroll taxes aren't company money, they are taxes withheld from employee paychecks...
    Half correct. Those percentages have also increased, and the employer matches them. It appears your source effectively shifted the percentage to the individual and away from the corporate tax burden.

  21. #21
    W4A1 143 43CK? Nbadan's Avatar
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    Half correct. Those percentages have also increased, and the employer matches them. It appears your source effectively shifted the percentage to the individual and away from the corporate tax burden.
    Are you really comparing gains from corporate tax loop-holes to rises in the SS tax?

  22. #22
    Spur-taaaa TDMVPDPOY's Avatar
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    no laws are broke, just wankers hating on wankers who know how to exploit the law with taxation avoidance schemes....hey if the system is not correct, you cant stop ppl from exploiting the system

  23. #23
    Veteran Wild Cobra's Avatar
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    Are you really comparing gains from corporate tax loop-holes to rises in the SS tax?
    No, just present the untainted facts please.

  24. #24
    Alleged Michigander ChumpDumper's Avatar
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    So no laws were broken.

  25. #25
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    just curious if anyone had any thoughts on how to close the loophole.

    This is such a super old thing, if it was as easy as saying, no more loophole, it would have happened by now.

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