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Corporate Tax Inversions
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JayMillz Offline
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Post: #26
RE: Corporate Tax Inversions
(08-06-2014 04:05 AM)ElBorrachoInfamoso Wrote:  Let's stick to the real issue.

The real issue is corporations using inversions to shelter income for financial gain. I am unaware of corporations using inversions to shelter income because they have some sort of ideological predisposition towards how tax dollars are spend.

If you can provide some examples of inversions that occur because of the reasons that you listed such as "bombs to kill brown people" I would be interested in seeing that, particularly given the role that these corporations play in the military industrial complex.
08-06-2014 06:48 AM
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Menace Offline
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Post: #27
RE: Corporate Tax Inversions
It is a mistake to ascribe any morality to corporations, or require them to be ethical. They are amoral entities created for the purpose of limiting legal liability, organization, and maximizing profits.
08-06-2014 07:00 AM
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JayMillz Offline
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Post: #28
RE: Corporate Tax Inversions
http://www.washingtonpost.com/business/e...story.html

U.S. policymakers gird for rash of corporate expatriations
Lori Montgomery ∙ Washington Post ∙August 6


Washington policymakers are bracing for a wave of corporations to renounce their U.S. citizenship over the next few months, depriving the federal government of billions of dollars in tax revenue and stoking public outrage ahead of the Nov. 4 congressional elections.

So far this year, about a dozen U.S. companies — including such well-known brands as Medtronic medical devices and Chiquita bananas — have merged with foreign firms and shifted their headquarters offshore to avoid U.S. taxes, analysts say. Dozens of additional deals are in the works, according to administration and congressional officials, and other companies are quietly contemplating the move.
08-06-2014 10:32 AM
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monster Offline
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Post: #29
RE: Corporate Tax Inversions
To me the point is not so much whether they are moral or not, but whether they are legal or not.

It's common knowledge that corporations will minimize their tax burden in every way possible in order to maximize their profits. This is understandable. If tax inversions are legal than corporations will do that. And god knows how most tax revenue is wasted by the government rather than put to good use.

Therefore, I do not blame corporations. I blame our politicians.

It is our politicians fault that tax inversions are legal. These politicians, who are supposed to be "for the people" are actually just pandering to lobbyists and other special interests rather than doing their job to actually look out for American economic and tax fairness. Instead of acting "for the people" these politicians are cheating America out of billions upon billion of dollars by acting against true American interests through allowing tax inversions to be legal.
08-06-2014 10:41 AM
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ElBorrachoInfamoso Away
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Post: #30
RE: Corporate Tax Inversions
(08-06-2014 06:48 AM)JayMillz Wrote:  
(08-06-2014 04:05 AM)ElBorrachoInfamoso Wrote:  Let's stick to the real issue.

The real issue is corporations using inversions to shelter income for financial gain. I am unaware of corporations using inversions to shelter income because they have some sort of ideological predisposition towards how tax dollars are spend.

If you can provide some examples of inversions that occur because of the reasons that you listed such as "bombs to kill brown people" I would be interested in seeing that, particularly given the role that these corporations play in the military industrial complex.

Wrong again Jay.

You are claiming that the following statement is true:

1. Government should be allowed to steal more from corporations

However, you have failed to prove this second statement:

2.
Government should be allowed to steal more from someone

If the second statement is false then the first statement must be false. Proving the first statement is the issue here and I have shown you that the first statement must be false if the second statement is false. I also explained why the second statement is false.

Government should not be allowed to steal more from anyone, because government has already proven that it will not spend that money in a way that produces value for society. In economic terms, the marginal value of more government is less than 1.

You continue to push government propaganda on this issue but you are basing that propaganda on untenable assumptions.

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-Project Pat
08-08-2014 04:37 AM
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Dragonstone Offline
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Post: #31
RE: Corporate Tax Inversions
One issue I have with the campaign against "Inversions" is how Congress is going to define these transactions. Historically, going back to the "Excessive Compensation" rules and the "Greenmail" rules, this is not always a simple task.

Just to throw out an example: Company A is traded on a US stock exchange, headquartered in the US, and is owed by 80 percent US shareholders. Company A merges with Company B, traded on a non-US stock exchange, headquartered in Ireland, and is 0 percent owned by US shareholders. The resulting Company C doesn't trade on a US stock exchange, has some of it's officers in the US and some in Ireland, and is owned by 49 percent US shareholders. It claims Ireland as it's headquarters.

How should Congress treat this company?
08-09-2014 08:14 PM
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JayMillz Offline
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Post: #32
RE: Corporate Tax Inversions
http://www.washingtonpost.com/business/e...ead&wpmm=1

When companies flee U.S. tax system, investors often don’t reap big returns

Looking back three decades at 52 completed transactions, the review showed 19 of the companies have subsequently outperformed the Standard & Poor’s 500 index, while 19 have underperformed. Another 10 have been bought by rivals, three have gone out of business and one has reincorporated in the United States.

Drugmakers are dominating the latest wave of inversions, and most of them have outperformed the benchmark index. So far in this year, five U.S. pharmaceutical firms have agreed to redomicile to Ireland, Canada or the Netherlands. Deals that have not been completed were excluded from the review.

It is impossible to know how the companies might have fared in the market had they not inverted. But the analysis makes one thing clear: Inversions, on their own, despite largely providing the tax savings that companies seek, are no guarantee of superior returns for investors.

On Aug. 6, for example, after months of internal debate and public criticism from politicians, U.S. retailer Walgreen said it would not reincorporate in Europe. Drugmaker Pfizer and advertising firm Omnicom Group, which are U.S. leaders in their industries, also have walked away from planned inversions recently months because they couldn’t reach deals with their targets.

Inversion destinations have lower corporate tax rates than the United States. The top U.S. rate of 35 percent is among the world’s highest. Still, many U.S. companies pay far below that headline rate because of abundant loopholes that give businesses, especially big ones, a lower effective tax rate.
08-19-2014 10:10 AM
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ElBorrachoInfamoso Away
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Post: #33
RE: Corporate Tax Inversions
http://www.zerohedge.com/news/2013-06-21...rned-money

The Waste List: 66 Ways The U.S. Government Is Blowing Your Hard-Earned Money


Why did the U.S. government spend 2.6 million dollars to train Chinese prostitutes to drink responsibly? Why did the U.S. government spend $175,587 "to determine if cocaine makes Japanese quail engage in sexually risky behavior"? Why did the U.S. government spend nearly a million dollars on a new soccer field for detainees being held at Guantanamo Bay? This week when I saw that the IRS was about to pay out 70 million dollars in bonuses to their employees and that the U.S. government was going to be leaving 7 billion dollars worth of military equipment behind in Afghanistan, it caused me to reflect on all of the other crazy ways that the government has been wasting our money in recent years. So I decided to go back through my previous articles and put together a list. I call it "The Waste List".

I've got the dick so I make the rules.
-Project Pat
08-22-2014 04:15 AM
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JayMillz Offline
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Post: #34
RE: Corporate Tax Inversions
http://www.bloomberg.com/news/print/2014...s-tax.html

Boehner, Camp Profit From Corporate Bid to Avoid U.S. Tax
Richard Rubin ∙ Bloomberg ∙ Aug 26, 2014

Two top Republican lawmakers profited from a corporate tax-avoidance maneuver that the U.S. Treasury Department is seeking to curb. While U.S. House Speaker John Boehner and Ways and Means Committee Chairman Dave Camp have resisted calls for a crackdown on companies adopting overseas addresses to pay lower taxes, both have made money off one of the deals. They also have investments at risk of losing value because of government action. .... A Bloomberg News review of public filings of congressional leaders and members of the tax committees found at least five other lawmakers with investments in companies involved in inversion deals.
08-26-2014 08:54 AM
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RexImperator Offline
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Post: #35
RE: Corporate Tax Inversions
Burger King is going Canadian:

http://www.usatoday.com/story/money/busi.../14608907/

Quote:The new base in Canada could allow Burger King (BKW) to reduce its U.S. tax bill -- a recent report by KPMG found that total tax costs in Canada are about 46% lower than in the U.S.

Somehow I thought they were a UK company, but I don't follow this stuff too closely.

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08-26-2014 10:31 AM
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Dragonstone Offline
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Post: #36
RE: Corporate Tax Inversions
(08-26-2014 10:31 AM)RexImperator Wrote:  Somehow I thought they were a UK company, but I don't follow this stuff too closely.

According to Burger King Worldwide, Inc.'s last 10-K Annual Report, they are registered in Delaware and headquartered out of Miami, FL.

The link to the annual reports from the company's investor relations website:

http://investor.bk.com/conteudo_en.asp?i...tipo=43575

I didn't realize this, but Burger King apparently "refranchised" all but 52 restaurants around Miami, and is mainly collecting royalties and rental income. If I'm reading the numbers correctly, more than half of all of the locations as of 12/31/2013 are in the US & Canada.
08-26-2014 10:47 AM
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monster Offline
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Post: #37
RE: Corporate Tax Inversions
It's funny that Warren Buffet is funding BK's tax inversion because Buffet is the one who's always saying corporations & wealthy should be taxed more! What a load of horse!

http://www.zerohedge.com/news/2014-08-26...rsion-deal
08-26-2014 11:16 AM
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RexImperator Offline
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Post: #38
RE: Corporate Tax Inversions
(08-26-2014 10:47 AM)Dragonstone Wrote:  
(08-26-2014 10:31 AM)RexImperator Wrote:  Somehow I thought they were a UK company, but I don't follow this stuff too closely.

According to Burger King Worldwide, Inc.'s last 10-K Annual Report, they are registered in Delaware and headquartered out of Miami, FL.

The link to the annual reports from the company's investor relations website:

http://investor.bk.com/conteudo_en.asp?i...tipo=43575

I didn't realize this, but Burger King apparently "refranchised" all but 52 restaurants around Miami, and is mainly collecting royalties and rental income. If I'm reading the numbers correctly, more than half of all of the locations as of 12/31/2013 are in the US & Canada.

Apparently at one point they were owned by Grand Metropolitan and Diageo, and that's why I thought that:

https://en.m.wikipedia.org/wiki/History_of_Burger_King
08-26-2014 11:41 AM
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Bad Hussar Offline
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Post: #39
RE: Corporate Tax Inversions
(08-26-2014 11:16 AM)monster Wrote:  It's funny that Warren Buffet is funding BK's tax inversion because Buffet is the one who's always saying corporations & wealthy should be taxed more! What a load of horse!

http://www.zerohedge.com/news/2014-08-26...rsion-deal

Not that I know him, obviously, but his viscous reaction to a stepdaughter who participated in a TV show on the rich and famous as a young woman seems to indicate he is not the nice kindly man he projects himself as.

Could be that he is just very cynical and is burning bridges behind him in the hope that his wealth and accomplishments can't be surpassed by others coming later. Pretty strange thing to do for a man his age, but it's possible. Like they say: Watch what someone does, not what they say.
08-27-2014 11:57 AM
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JayMillz Offline
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Post: #40
RE: Corporate Tax Inversions
http://dealbook.nytimes.com/2014/08/28/b...blogs&_r=0

Businesses Are Winning Cat-and-Mouse Tax Game
DAVID GELLES ∙ New York Times ∙ AUGUST 28, 2014 7:45 PM

... Across corporate America, companies large and small are finding new ways to address one of the business world’s oldest irritations: paying taxes. By exploiting existing loopholes and devising new ones, some of the country’s best-known companies are making it harder than ever for the federal government to replenish its already depleted coffers. As a result, business income tax revenue remains stagnant at about 2 percent of gross domestic product even as corporate profits hit records. Business taxes now make up less than 10 percent of federal revenue, and in some years as little as 6.6 percent. That is sharply down from the years after World War II, when about 30 percent of federal revenue came from corporate taxes.
08-29-2014 09:02 AM
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ElBorrachoInfamoso Away
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Post: #41
RE: Corporate Tax Inversions
Here's an interesting site to look up many of the items that government wastes your money on: http://thewastelist.nrcc.org/

One particularly egregious example
Quote:$3 Million In Taxpayer Money To Lobby For Soda Tax - $3,000,000

The New York Department of Health used a $3 million taxpayer-funded grant to lobby for a soda tax initiative.

Not only is the government stealing your money, but it is using your money to convince itself to steal more of your money whenever you're in the mood for a coke.

Promote corporate tax inversions so government has less money to waste on this frivolous garbage.

I've got the dick so I make the rules.
-Project Pat
09-05-2014 10:46 AM
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DannyAlberta Offline
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Post: #42
RE: Corporate Tax Inversions
perhaps as a canadian businessman i can lend a different perspective.

tax inversions are a result of capital flight. certain businesses relocate assets, people, etc to a different jurisdiction where they can operate on more favourable terms.

for years canada was a victim of capital flight. this was because in the 70s and 80s our corporate taxes were relatively higher than the usa and other western jurisdictions. years of this convinced the federal liberal and later conservative governments that they had to be more competitive, which led to a slow but steady lowering of corporate rates. some provinces like ontario raised provincial rates to fill the void, but relatively speaking the rates are still lower than they used to be. the avg corporate rate in canada is now in the mid-twenties, where in the usa it is almost forty.

so for the first time in my life, although this happened gradually, canada is an much more attractive jurisdiction than the usa for corporate taxation. hence we see the burger king inversion. possibly we will see more.

i do sympathize with many of the posters in this thread who lament the lost tax revenue for their home country. corporate taxes are valuable for a nation with deficit spending troubles. however, the current Obama administration seems a little bit naïve to think that in today's increasingly global and mobile economy, corporate actors are going to endlessly endure a jurisdiction that is highly uncompetitive compared to other western nations. even the britain is now noticeably lower in corporate tax rates.

corporations have no loyalty other than to the people who invest in them and the customers who fund them. sometimes not even then. to expect them to endure less profitability out of patriotism or a duty of loyalty to a country where they made their initial inroads is not logical, rational or economic thought.

so the administration has 3 choices: 1 do nothing, which they will catch heavy flak for as more inversions are likely to happen; 2 try to get competitive by lower taxes, an option which the current administration appears totally unenthused about; and 3 find ways to make it more difficult/outlaw it. i personally think option 3 is the most likely.

option 3 might cause huge blowback on two fronts however. first, if they engaged in any grandfathering or delayed implementation of new regulations at all, this will give companies who aren't already planning an inversion time to do so and may increase inversions in the short term. second, the regulation or outlawing of inversions makes it less likely that the usa will attract new foreign investment.

not an easy problem and not an easy solution of course. i just wish they would give some - any, consideration to lowering the rate to a competitive level to see if that can attract more investment. sadly i think that is not in the cards with the current us administration.

edit: i should have added that my country may see its comparative advantage come to an end shortly once justin trudeau becomes our new pm next yr. given his "progressive" inclinations, he may start raising rates again.
(This post was last modified: 09-05-2014 12:11 PM by DannyAlberta.)
09-05-2014 12:07 PM
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JayMillz Offline
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Post: #43
RE: Corporate Tax Inversions
http://online.wsj.com/articles/sen-schum...#printMode

Sen. Schumer Proposes Limiting Benefits of So-Called Inversion Transactions
JOHN D. MCKINNON ∙ Wall Street Journal ∙ Sept. 7, 2014

A top Senate Democrat is considering limits on deductions and other tax breaks for companies that move out of the U.S. for tax purposes, but he faces long odds in advancing the measure as Congress returns to Washington this week. Sen. Charles Schumer (D., N.Y.) would discourage companies from moving by limiting some of the big tax benefits of so-called inversion transactions, according to a draft of his bill circulating in Washington over the weekend and reviewed by The Wall Street Journal. Mr. Schumer outlined his intentions for the legislation last month.
09-08-2014 09:13 AM
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Dragonstone Offline
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Post: #44
RE: Corporate Tax Inversions
The parts of Sen. Schumer's proposal that have been leaked/released is interesting. According to the Bloomburg article, Sen. Schumer's proposal will toughen the 163(j) related-party and earnings-stripping interest deduction rules, which in the grand scheme of things could throw the proverbial wrench into the US operations of an "inverted corporation". Another portion of the rules that would also have an impact is that it would apply to companies who carried out inversions since 1994. It's not clear from the article why that date was selected. The proposal would also define an "inversion", which appears to currently be the major stopping point preventing the proposal from being released.

The bloomburg article (no paywall) is below:
http://www.bloomberg.com/news/2014-09-07...-1994.html

There's supposed to be a provision in the proposal relating to a requirement for IRS pre-approval of intra-corporate transfers for companies subject to the proposal, but I'd like to see the details of that before commenting further.

On a side note, if this proposal actually would become law, presumably in the next congress, it would possibly borrow revenue from Rep. Camp's Corporate Tax Reform proposal, since persistent rumors suggest that Rep. Camp's proposal is in large part "offset" by revenue gains from reducing the interest deduction for corporations. That alone might be enough to stop Sen. Schumer's proposal, in whatever form it reaches the legislative floor.
09-08-2014 10:59 AM
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ElBorrachoInfamoso Away
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Post: #45
RE: Corporate Tax Inversions
Another interesting article on government waste

The More Wasteful Is The Federal Government Program, The More Essential It Is To Washington

More egregious examples of how government spends the money it steals from you.
Quote:HUD used $65 million in emergency funds approved after Hurricane Sandy to purchase tourism ads for New Jersey and New York. The Federal Aviation Administration spent $3.5 million on solar panels for the Manchester-Boston Airport, many of which have to be covered because the glare impedes air traffic controllers. The State Department devoted $630,000 to generate additional Facebook “Likes.” NASA allocated nearly $400,000 to create the cartoon superhero “Green Ninja,” dedicated to fighting climate change.

If you care about having a strong American economy, then support tax inversions so the US government has less money to waste on these programs that are a drain on the American people.

I've got the dick so I make the rules.
-Project Pat
09-09-2014 06:00 AM
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Phoenix Offline
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Post: #46
RE: Corporate Tax Inversions
That's the beauty of not living in a one-state world. If one state is too parasitic, it's subjects can simply move to another less parasitic one.

Every state hates this, which is why on the extreme end you see them preventing their subjects leaving (e.g. East Germany). The US trying to punish corporations from leaving, instead of lowering the tax rate, is just another step towards this extreme.

Still waiting for you Americans to have that Article 5 convention to reign in the Federal government.
09-09-2014 06:28 AM
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RexImperator Offline
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Post: #47
RE: Corporate Tax Inversions
I think I would support a zero % corporate tax in exchange for making the rates on capital gains the same as regular income and ending the carried interest loophole.

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09-09-2014 08:57 AM
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ElBorrachoInfamoso Away
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Post: #48
RE: Corporate Tax Inversions
(09-09-2014 08:57 AM)RexImperator Wrote:  I think I would support a zero % corporate tax in exchange for making the rates on capital gains the same as regular income and ending the carried interest loophole.

That would only be a definite improvement if regular income tax rates dropped to a reasonable level closer to 10% for the highest bracket i.e. the level needed to support just those few government services that actually produce value for taxpayers.

Without lowering personal income tax rates, it's not clear that your solution is better than the current situation.

I've got the dick so I make the rules.
-Project Pat
09-09-2014 02:59 PM
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Bad Hussar Offline
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Post: #49
RE: Corporate Tax Inversions
(09-09-2014 08:57 AM)RexImperator Wrote:  I think I would support a zero % corporate tax in exchange for making the rates on capital gains the same as regular income and ending the carried interest loophole.

Interesting proposal. I'm also more or less in favour of "flat rate" taxation with income, capital and corporate rates all the same with no progression in rates as income increases. But also.....

Corporations obviously have various deductions they can make against their income. In my opinion individuals should have a basic annual minimum deduction for purposes of determining income for state/provincial and federal income tax purposes equal to $Minimum Wage Rate x 2000 hours. In most jurisdictions now the "working poor" pay income tax, which is beyond ridiculous and a wake up call for anyone who believes a government when they tell them that a newly introduced tax will only be applied to "the rich". This was the same argument when income tax was introduced, but now we have people working on the floor at McDonalds/Walmart paying income tax. It really is not fair or equitable. They will already pay consumption taxes (GST/VAT) and various other levies and taxes built into almost all consumer goods and services. It's not like they don't pay. But someone not earning very much cannot afford to pay income taxes.
09-15-2014 01:24 PM
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JayMillz Offline
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Post: #50
RE: Corporate Tax Inversions
http://www.washingtonpost.com/business/e...story.html

Obama hits at companies moving overseas to avoid taxes
By Lori Montgomery, Washington Post, September 22

The Obama administration took action Monday to discourage corporations from moving their headquarters abroad to avoid U.S. taxes, announcing new rules designed to make such transactions significantly less profitable. The rules, which take effect immediately, will not block the practice, and Treasury Secretary Jack Lew again called on Congress to enact more far-reaching reforms. But in the meantime, he said, federal officials “cannot wait to address this problem,” which threatens to rob the U.S. Treasury of tens of billions of dollars….
09-23-2014 10:19 AM
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