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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 7:45 pm 
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http://www.europeaninsuranceforum.com/s ... monn-odea/



Eamonn O'Dea
of the International division of the Revenue Department.

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IMHO, part of the problem, part of the big system that has led to gross unfairness, morally and probably unjustly, in the Irish Taxation mess that is present.

He did a Morning Ireland interview at the end of last week on RTE Radio 1 where he played out the political line on behalf of TPTB of which he is clearly a part as the Apple story was breaking.
http://www.irishtimes.com/business/tech ... -1.2774804

One to watch out for if you come across him.

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 8:04 pm 
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Quote:
Exploitation
2pack. What a fucking wonderfully inept and inappropriate use of the word.

Apart from the smiling in the meetings as the ladies and lads from Mephistopheles explained how things work here..

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 10:18 pm 
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wii4miinow wrote:
http://www.europeaninsuranceforum.com/staff/eamonn-odea/



Eamonn O'Dea
of the International division of the Revenue Department.

Image

IMHO, part of the problem, part of the big system that has led to gross unfairness, morally and probably unjustly, in the Irish Taxation mess that is present.

He did a Morning Ireland interview at the end of last week on RTE Radio 1 where he played out the political line on behalf of TPTB of which he is clearly a part as the Apple story was breaking.
http://www.irishtimes.com/business/tech ... -1.2774804

One to watch out for if you come across him.


It's not unheard of for senior Revenue to retire and then work for the top tax consultants....

I think the recruiters in those practices will be watching out


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 11:22 pm 
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Joined: Feb 21, 2008
Posts: 4278
Here is an interesting list of current high tech players in Ireland..

http://www.top1000.ie/industries/technology

The really interesting number is revenue per employee.

You have to go down to number 12 before you find Intel, who actual do something substantive in Ireland. Their revenue per employee is around $500K... which is not bad. Any company whose Irish operation has a revenue per employee much above that is a tax scam operation. Which is almost all of them.

Bear in mind that MS et al also have brass plate operations in Ireland whose revenue is often greater than that of the "official" subsidiary. In MS's case before they hid it in embarrassment by making it a private company it had at least twice the revenue of the "ligit" subsidiary.

Its tax shells all the way down..


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 11:50 pm 
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I see we're on the Brian Lucey twitter now Ted

brian lucey ‏@brianmlucey 4h4 hours ago

Ok, I know , its Saturday evening. But please, do read this thread on #AppleTax viewtopic.php?f=4&t=66347
Really quite excellent
24 retweets 28 likes

Owen Callan
‏@OwenCallan

@brianmlucey @WhelanKarl "Excellent"? Christ, it's awful. It's a weird mix of facts, quasi facts, and complete bollox.

Retweet
1
Likes
2
Andy
BMJF
James

11:24 PM - 3 Sep 2016
1 retweet 2 likes
Urlofcork Tweet text

@OwenCallan @brianmlucey @WhelanKarl Does anyone want to name Observer35

Add photos or video
67

brian lucey ‏@brianmlucey 16m16 minutes ago

@OwenCallan @WhelanKarl aka the pin. The nuggets though...


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 7:29 am 
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brian lucey ‏
Quote:
brianmlucey 16m16 minutes ago

@OwenCallan @WhelanKarl aka the pin. The nuggets though..


Wait, did Brian Lucey's just imply the Pin was a mix of facts, quasi facts and complete bollox??

I guess Brian has learned his lesson from endorsing complete bollox he read on the interwebs. e.g. his Eircode screed, the deposits are an asset brainfart


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 8:18 am 
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Posts: 5210
slasher wrote:
Wait, did Brian Lucey's just imply the Pin was a mix of facts, quasi facts and complete bollox??

No, that was Owen Callan.

It's not a bad description of the Pin, except he missed out opinions, wild rants and tinfoilhattery. :D

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 8:42 am 
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Eschatologist wrote:
slasher wrote:
Wait, did Brian Lucey's just imply the Pin was a mix of facts, quasi facts and complete bollox??

No, that was Owen Callan.

It's not a bad description of the Pin, except he missed out opinions, wild rants and tinfoilhattery. :D



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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 8:54 am 
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discostu wrote:
I see we're on the Brian Lucey twitter now Ted

brian lucey ‏@brianmlucey 4h4 hours ago

Ok, I know , its Saturday evening. But please, do read this thread on #AppleTax viewtopic.php?f=4&t=66347
Really quite excellent
24 retweets 28 likes

Owen Callan
‏@OwenCallan

@brianmlucey @WhelanKarl "Excellent"? Christ, it's awful. It's a weird mix of facts, quasi facts, and complete bollox.

Retweet
1
Likes
2
Andy
BMJF
James

11:24 PM - 3 Sep 2016
1 retweet 2 likes
Urlofcork Tweet text

@OwenCallan @brianmlucey @WhelanKarl Does anyone want to name Observer35

Add photos or video
67

brian lucey ‏@brianmlucey 16m16 minutes ago

@OwenCallan @WhelanKarl aka the pin. The nuggets though...



WTF is a quasi fact?? :shock:


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 9:01 am 
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Too Big to Fail

Joined: Feb 21, 2008
Posts: 4278
Eschatologist wrote:
slasher wrote:
Wait, did Brian Lucey's just imply the Pin was a mix of facts, quasi facts and complete bollox??

No, that was Owen Callan.

It's not a bad description of the Pin, except he missed out opinions, wild rants and tinfoilhattery. :D


So just like http://www.irisheconomy.ie, except with far less academic pseudo-scientific econometric bolloxs. Remember, when a non applied mathematician wraps what is essentially little more than political / ideological opinions in very fancy equations this does not make it "science". Or maths for that matter. It is still a political opinion. Wrapped in unprovable equations. Misrepresented as scientific.

And thats about 95% of modern economics.

At least in the old days they had the honesty to call the discipline political economy, i.e.. a social science. Just like sociology or anthropology.

Our bollox does not have affectations of self-importance.


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 9:45 am 
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Location: The Second Æther! Hull Breach Imminent, Eschaton Immanent...
Inis Man wrote:
WTF is a quasi fact?? :shock:

That one's from Owen Callan, so I wouldn't waste energy trying to interpret!


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 9:52 am 
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Col. Max Pyatnitski wrote:
Inis Man wrote:
WTF is a quasi fact?? :shock:

That one's from Owen Callan, so I wouldn't waste energy trying to interpret!

It's the half-truth's weird cousin,?


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 10:37 am 
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Posts: 4278
The US Treasury "White Paper" is very interesting, you can find it here..

https://www.treasury.gov/resource-center/tax-policy/treaties/Documents/White-Paper-State-Aid.pdf

First, the guy who stuck his name to the top of the paper is someone with a law degree who is a career party hack. Started in Tip O'Neils office back in the '70s, part of every Dem administration since, and who's only foray into the business world was a few years before the '08 Crash at City running a division that specialized in operating very creative derivative vehicles through some of the most scenic tax havens in the Caribbean. An odd choice for COO in so many ways. Or maybe not.

So the classic current administration Pay to Play operative. So no mystery about the paper or its tenor.

Next the executive summary. After reading the three points my reaction was, is that all you've got? The main complaint is that the EU is "not playing by the rules". Except that each of the three "complaints" has been committed on multiple occasions by both the Treasury, Executive and US Courts in the past going back many decades. The US has a very long history of all three complaints and has acted on multiple occasions in the past where it considered US law and US ruling as having precedent over foreign law, international conventions, and have been applied retroactively.

So the papers position is the legal equivalent of clutching at straws.

The rest of the paper only mentions Apple in passing and makes a long of case law arguments about why none of the other US companies under investigation are guilty. Its almost all about the other companies. The paper makes no real attempt to defend Apple because they really have no defense from case law.

One first reading the biggest weakness for the Treasury position is the first test for state aid "(1) is financed by the State or through State resources". They are trying a defense using a facile reading of this test.

In the real world if we have company A and company B. And both would owe $100M in tax if operated in a standard trading manner. That is $200M on the states balance sheet. A tangible asset. Now if the state decided to forgo collecting that $100M for company A that is a net transfer of tangible assets from the state to company A. That $100M in tax owed would be a liability on company A's balance sheet. That transfer of $100M, the nullification of the tax liability by the state, is under the definition of state aid state financing of company A no matter how you try to cut it. But I'm sure the lawyers will spend years arguing otherwise.

Now company B pays its $100M in tax. Thats the selectivity test satisfied. Apple had a different tax regime from Google, MS etc..

Scale up and add lots of complications but thats the legal position in a nutshell.

Starbucks and Amazon will probably get off eventually but Apple with their cute hoor stunt of a null tax residency are basically fucked. The only thing that will save Apple is a very long war of legal attrition. Which I am sure they are gearing up for.


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 11:13 am 
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Who knows for sure. Maybe a Quasi fact is a fact that hangs out in bell tower in Notre Dame ?


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 11:15 am 
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jmc wrote:
Here is an interesting list of current high tech players in Ireland..

http://www.top1000.ie/industries/technology

The really interesting number is revenue per employee.

You have to go down to number 12 before you find Intel, who actual do something substantive in Ireland. Their revenue per employee is around $500K... which is not bad. Any company whose Irish operation has a revenue per employee much above that is a tax scam operation. Which is almost all of them.

Even back in the early 90s when I used to know some folk at Apple Ireland, they used to cite $1m revenue per employee.

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