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They don't pay double tax. They get full credit for any foreign taxes paid. The reason it looks like "double taxation" is due to so much overseas profit being funneled through tax haven countries such as Ireland, where they basically pay nothing and therefore don't get much credit for taxes paid.

Not exactly. The way the tax code is both written and, effectively works, it mitigates, not eliminates, double taxation. You are correct about the ability to use FTC or deduct foreign tax paid, but there are limitations so that it doesn't always work out 1:1 as you suggest. Double taxation is real, not a red herring as you say. It's not a huge % of the total tax bill either but what rational person wants to pay more than they owe? Add in corporate fiduciary duties and activist shareholders to the stew.
 
Basically, for many US companies, Europe = Ireland.

I dont think so. My feeling is that everone major US Company that needs a foot in the European market has a headquarter in London.
 
I dont think so. My feeling is that everone major US Company that needs a foot in the European market has a headquarter in London.
I know that the UK also exists for many US companies because they speak English natively. But it is not their favorite, low-cost place, at least when it comes to big IT operations.
 
Not exactly. The way the tax code is both written and, effectively works, it mitigates, not eliminates, double taxation. You are correct about the ability to use FTC or deduct foreign tax paid, but there are limitations so that it doesn't always work out 1:1 as you suggest. Double taxation is real, not a red herring as you say. It's not a huge % of the total tax bill either but what rational person wants to pay more than they owe? Add in corporate fiduciary duties and activist shareholders to the stew.

I didn't call it a red herring. No need to exaggerate my point.

Whether credit for foreign taxes paid always works out 1:1 is hardly the issue, because that is obviously going to a function of quarterly variability in effective tax rates. But the fact is, a company can take a full deduction against earnings in the quarter when the foreign tax is paid. If the company later repatriates the earnings then they will pay tax on that amount at whatever is their corporate tax rate for that quarter. What they are not doing is paying tax on the tax, because they have already subtracted it from earnings.

The reason for raising this point is because it is generally not part of the discussion about the repatriation of overseas earnings, which often turns into a debate about the need for "tax holidays" due to "double taxation." The other point not often raised in these discussions are the tax havens that deflate tax rates for companies and thus expose them to a larger differential tax bill for repatriation. As a matter of public policy I don't see the argument for providing companies with overseas tax havens on the one hand, then forgiveness for the taxes they avoided paying on the other. Just because companies want that (for obvious reasons), doesn't mean they should get it.
 
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Great, what I don't want is software that is stripped from so many features that it becomes a PITA not to use because the GUI might be bloated, but because it doesn't assist me in the ways that are necessary for my way of thinking/operating and the amount of pictures I have and how I work with photos.

Aperture was this close to perfect in relation to organization tools, sure it lacked on the RAW processor and other features needed to keep it up to snuff, but it's a real shame Apple dropped it.

And whilst you are busy telling me how I supposedly overlook that other people might be content with it, I'm wondering why you assume that I'm trying to speak for everyone, because I am not.
If anything, Apple calling this the replacement for iPhoto AND Aperture signals they are trying to "one size fits all" me, which is an abomination in spite of their excellent work deliberatly making a consumer product (iPhoto) and one for very demanding folks (Aperture) before that.

Oh and don't worry, I'm not too busy complaining about this, if I was I'd be filling the forums non-stop about this awful move.
I'm still running Aperture, but God knows how long Apple is willing to drag along those who fail to find a reasonable replacement.
Yes that's right, still haven't found one, that's how good Aperture was.

This is beyond "but XYZ doesn't look as beautiful"...
We're talking functionality and speed of workflow here, because let me tell you, Aperture isn't nice to look at, it is for what it is, but it's not the "out of your sight"-kind of eye candy content-centric GUI.
And that, amongst other things, is what makes the application work so well.

I'm glad your girlfriend is happy with the software, but with all due respect, that doesn't help me jack with my database and its future and you'll understand that I'm more than annoyed to have been dropped by Apple like a hot potatoe with all the work I put into my collection, many parts of which are untransferable to Apple Photos.

I've sworn myself to remember this very well for future considerations regarding investing time and money into their products, because they seem to care very little about how you transition out once something's gone.
As long as they still unofficially drag Aperture around, like not kicking it out of iTunes integration, patching the OS around it more or less undocumented, etc ... they still have time to impress and correct this course again in some way, but right now I'm more eagerly awaiting what Affinity do with the DAM they are working on.

Glassed Silver:ios
I morn the passing of Aperture too, but Apple never claimed that Photos was meant to replace it. They took the unusual step of advocating that people move to Lightroom-- and I really, really don't want to.

Is Aperture still behaving itself for you? I've been getting increasingly more glitches under El Cap and I'm starting to worry I'm hanging on too long...
 
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I morn the passing of Aperture too, but Apple never claimed that Photos was meant to replace it. They took the unusual step of advocating that people move to Lightroom-- and I really, really don't want to.

Is Aperture still behaving itself for you? I've been getting increasingly more glitches under El Cap and I'm starting to worry I'm hanging on too long...
Well, you're right actually, then again it doesn't really help the matter.

Especially not when their proposed path loses you data, yes, beyond of course losing the non-destructive edits. (biggie!)

It's behaving nicely for me actually and it had been shown that Aperture is actually being worked around at Apple, regarding OS X.
I think someone spotted it in some release notes for some beta of El Crap that they moved from making Aperture fit OS X to OS X fitting Aperture providing a sort of unofficial extended soft support.

Apple better keep doing this until there's a reasonable replacement or my emotional attachment to the company may be gone sometime.
They are if anything a shadow of their former selves, a real shame.

Glassed Silver:mac
 
Apple's proposed partner, STMicroelectronics make some of the sensors for the more professional end of Leica cameras, like the M240/262 range (and maybe other Leica cameras but there is a lot of secrecy on who designs and makes what). However these were not designed in house but by a third party sensor designer based in Belgium called CMOSIS. STM in Grenoble were the production and fab specialists.

Grenoble in the lower regions of the Alps may seem superficially like a nice place but there are a considerable number of sink estates, mostly occupied by people, whose origins are from north Africa, who after years of deprivation and discrimination, have become very alienated from French mainstream society. The alienated youth become easy targets for unscrupulous manipulators, seeking to radicalise them. It is not too long since there were race riots in Grenoble. Nice in the south of France, is very similar, where summer visitors only tend to see the glitzy sea front and not the "banlieues" further inland. It is from one of these that the perpetrator of the recent outrage in Nice, came from.
 
All of our ideas?????? Really????? Is playing some game the only thing in your life? Does it tell you what you are going to eat today, tomorrow?
How's about SOME of our Ideas.
No [IMHO frankly silly] computer game can last forever. It is a fad and will the next big thing will be along soon. Then Pokemon will be consigned to the dustbin of history.

Sorry you misunderstood the fact that I was joking. I don't even use a smartphone so I couldn't play this even if I wanted to waste my time and life.
 
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