Become a MacRumors Supporter for $50/year with no ads, ability to filter front page stories, and private forums.
Ah, but what if no one watches that European content? Best to require the streaming services to only let you watch two American shows for every European show you watch, to enforce the proper ratio.
 
TL;DR
You're wrong, start studying international tax law, world economics and world politics before you make mindless remarks.

The long version:
The US doesn't pay taxes indeed, but the US does make tax laws therefore the retaliations shouldn't be to the people or legal entities that follow the laws, but to the US that makes the law.

And I'm sorry, but your representation of the tax laws are wrong.
First, anybody with any US connection pays taxes over their world income. So if you where born in Belgium, lived there all your life, never went on holiday anywhere else, never earned a penny outside of Belgium, you still need to pay US taxes. Why? Because your grandparents where on a visit in the States and your mother was born 6 weeks early in the US. Therefore your mother has a US relation and right to a passport, therefore you have a US relation. This US connection is a bases for the US to tax the income you earn. This is called taxing on world income.
The only country that does that is the US. Oh, and Nigeria but do you really want me to compare Nigeria to the US?
People can not escape this: the US has this enforced by forcing banks world wide to declare US taxable people's income. If banks don't do that, the US will deny them access to dollar transactions, which in return will make a bank go bankrupt, so in effect you enforce it.

But following your advice to choose the most beneficial, I would say that most white Americans have European roots, therefore we are going to tax them on their world income, here in Europe, by European tax laws. So be prepared to pay us 58% of your income over your live long earnings!

But the real odd part is that the US-government also vehemently defends the rights of US corporations NOT to pay any tax anywhere in the world.
I will make an example of the double Irish with a dutch sandwich. No, this isn't a lunch sandwich with a nice Guinness.
It is a tax avoiding scheme where US corporations pay no tax in the country they earn their money, but neither pay tax in the US.
E.g. Apple sells an iCloud subscription in France. They do not pay VAT, they do not pay any profit tax in France, because they are "located" in Ireland. They have no substance in Ireland, or at least not any substance that is in line with their earnings. That is important because they can say that they are not really located there.

So what to do next? You don't want to pay the (lowest in EU) taxes in Ireland! Simple, you have a local entity that sells a service, then you send the profits to an Irish company, then on to a Dutch company and then back to a second Irish company headquartered in a tax haven.
These payments (that take out any potential profit) are on paper a payment for royalties, IP, minimal services etc. etc.
The end result is that there is a loss for the local entity that made the sale. So no taxes there and often a tax return or compensation for the loss.
Then there are no taxes for profits in the tax haven, so that is untaxed as well.

The real beauty in this scheme is here: US companies need to pay profit tax over their "world income". But they don't. Apple has at this moment a cash mountain of $252 BILLION in the island of Jersey. They can't touch this money, if they bring it back to the US they need to pay profit taxes. But as long as it stays in Jersey that's not problem.
So they wait until profit tax rates are lowered, and they are pushing hard for that.
But what good is money if you can't touch it?
Well, if they need money, they lend on the world markets with money on the island of Jersey as a security. They don't need to lend money, they have plenty from earnings in the US, but it can be cheaper to lend money for a ultra low interest (perhaps at times even negative, so you earn money lending) while they invest the tax money, earning them a bit as well.

That is how you don't pay taxes and earn money with money you shouldn't have had.
That is why France (and a few other countries) have introduced a e-commerce tax. And Trump didn't like that idea, so he retaliated by import taxing German cars (that did hurt), French cheese and wine (that hardly did hurt financially, but something to do with French pride), etc. etc. this in return went to the WTO, which Trump has made totally ineffective by vetoing appointment of judges as they might have slapped him on his tiny grubby grabbing hands. :-D
So the EU made a petty gesture back: you need 30% EU content on your streaming service because you'll wipe out EU culture. Or what ever dribble came from the EU commission for flimsy reasoning.

In the end it's all tit-for-tat petty behaviour, but it is about serious amounts of money. $252 Billion in profits was revealed in 2017 by the "paradise papers" and just for Apple. Imagine what Amazon, Google, Facebook, Insta, Snap and all the other nameless huge corporations have on that cash mountain?

You're wrong too in so many ways.
LOL You say I’m wrong and yet the first point is one of agreement. 🤣

And the second point you make you seem to have totally misread what I said and you bring in clear falsehoods.

You come across like you are so convinced about your point of view being right that you forget to read what others are actually stating.
 
Sorry, if they feel that American companies are not paying their share of taxes, they have a simple solution, they can raise taxes on them. France has proposed exactly that.

Sorry, this is simply not the case. U.S. citizens are taxed on their world wide income, with credit for taxes paid in other jurisdictions. "Someone born on a an American plane" might be able to claim U.S. citizenship (the case law on this not solid, and is even less clear if they were in international airspace), but they would have to apply for it and have it granted. Given that requires pretty serious actions, it is not something that would just happen.

Again, just not a true statement. The U.S. has a law that requires that any bank with deposits from American citizens report deposits and income earned, just like U.S. banks are required to do. It is a misguided law to prevent tax dodgers, but it does not "force banks to refuse services", there are some banks who choose not to take deposits from U.S. Citizens because they do not have enough of them and do not do any business in the U.S. and so do not want the hassle.

Having said that, this is only for U.S. citizens. Your hypothetical foreigner born on a U.S. Flag Carrier in international airspace or a woman whose baby was month premature and born in a U.S. hospital would not be a U.S. citizen unless they wanted to be.


You seem to conflate every accusation against every U.S. company. The big 5 studios have been making about the same number of movies for many years. Thanks to streaming and digital cinema distribution, there are way more independent and small productions then ever before. Unlike Europe, Canada, India and others, there are no local content rules for U.S. distribution, meaning that anyone who produces interesting content can freely distribute any where in the U.S. with no restrictions.

However, as I have said before, if you want to tax yourselves to pay local content producers to produce shows that are not economically viable, I have no problem with that. You can enact a tax on streaming services and use that revenue for it. Unfortunately, their is no consensus to do that, so instead they have proposed this back door solution.

As I said, were I in control of any of these streaming services, I would license tens of thousands of hours of cheap, old, library content from the smallest niches and make that available. I would not even bother to subtitle it. Make it only available in the original language.
Absolutely spot on. I’ve got lots of ties with the US, even used to be a working resident. But I’m no citizen, and haven’t resided for a long time. The IRS has no claim at all on my continued income.

And whilst working for a US bank but across Poland, Russia and UAE we happily provided services, but did report back indeed. Nothing that unusual there, many countries have such arrangements. HMRC in the UK also has reporting requirements. No big deal, well other than no being able to remain out of sight 🤣 and thus also not out of mind.
 
I’m guessing you live in some very big German city with a lot of migrants - I live in the countryside (Schwarzwald) and situation is completely reversed: very few people speak good English and local German television dominates.

It’s a bit of a cliché to say - but don’t assume that your big city bubble experience applies to the rest of the land.

I have also experience of French TV - and it is even more prominent than German.
I lived in both Hamburg and a tiny town with maybe 12 houses about 50 minutes from Trier, if you were under 40 you spoke English. Don't assume I only lived in a big city. The quality of German TV reminds me of British or American TV from 20 years ago. Germany had the best roads I've ever driven on but in some areas it felt decades behind the UK, banking is stone-age, internet was overpriced and awful, cellular networks were overpriced with inferior coverage.
 
  • Wow
Reactions: Maximara
Apple pays more taxes than any other company in the world. In Ireland, Apple accounts for 7% of all corporate tax revenue.
Which is what the next two lines I provided basically said:

"Although the corporate tax rate has been reduced, companies are still using tax loopholes to save money. This includes finding ways to shift U.S. profits to foreign subsidiaries in countries with lower tax rates, a practice known as an offshore tax-shelter."

In otherwords the US company is paying the taxes of the other country (ie paying the EU) to get out of paying the IRS.
 
Apple pays more taxes than any other company in the world. In Ireland, Apple accounts for 7% of all corporate tax revenue.
So 7% does make the 252 billion cash mountain go away? You think having thousands of billions in profit and not paying any taxes is fair?
And you are right that tax evasion isn’t illegal, but that dienst make it morally right. But it undermines the societies just as much as a blind “defund the police” does.

But also, the IRS says:
Amendment XIV, Section 1, Clause 1 of the U.S. Constitution directs that all persons born in the United States are U.S. citizens. This is the case regardless of the tax or immigration status of a person’s parents.

And:
Furthermore, a person born outside the United States may also be a U.S. citizen at birth if at least one parent is a U.S. citizen and has lived in the United States for a specified period.


being born on a us plane in international air is seen by the irs as being born on us soil.
There is no mention of needing to claim citizenship, you just are.
So your first assumption is proven wrong, therefore rendering your whole argumentation moot.

a few hundred people here have been refused a bank account this year. So it’s not some hypothetical point
 
  • Disagree
Reactions: cyb3rdud3
In otherwords the US company is paying the taxes of the other country (ie paying the EU) to get out of paying the IRS.
No, they are paying the absolute minimum. And the 7% was just because the got a 13,5 billion fine from the EU. Which they are fighting.
 
No, they are paying the absolute minimum. And the 7% was just because the got a 13,5 billion fine from the EU. Which they are fighting.
They paid what they agreed with the amount the government wanted them to pay. Heck, in the situation with Ireland it was Ireland not Apple who appealed the money grab by the EU. All this antitrust talk is theater to distract from the trust like behavior of the cable companies and ISPs that censor what they deem "inappropriate" with totally BS figleaves like calling breast cancer and rape counseling/information sites "porn" (look it up - this was a real thing back in 2011 and still happens today).
 
Last edited:
They paid what they agreed with the amount the government wanted them to pay. Heck, in the situation with Ireland it was Ireland who appealed the money grab by the EU.
It could only have been Ireland, Apple isn’t a party in that dispute. Apple would have to pay, but the EU commission ordered Ireland to claw back 13,5bln from Apple.
 
So 7% does make the 252 billion cash mountain go away? You think having thousands of billions in profit and not paying any taxes is fair?
You keep saying "not paying any taxes" even in the same paragraph where you acknowledge that they paid 7% of all corporate taxes paid in Ireland. How much Apple has not spent has nothing to do with how much they have paid or should pay in taxes.
And you are right that tax evasion isn’t illegal, but that dienst make it morally right. But it undermines the societies just as much as a blind “defund the police” does.
Tax evasion is illegal. Tax avoidance is not. Apple has paid all the taxes the governments involved say they owe. If you feel that they should pay more, you have every right to lobby your government to increase tax rates.
But also, the IRS says:
Amendment XIV, Section 1, Clause 1 of the U.S. Constitution directs that all persons born in the United States are U.S. citizens. This is the case regardless of the tax or immigration status of a person’s parents.
You are reading an information page from the IRS. I quoted the U.S. Code (the actual law that governs this). The 14th amendment guarantees that those born in the U.S. have the right to claim U.S. citizenship. That does not mean that they are required to claim it if they do not live here. As I also pointed out, renouncing U.S. citizenship is quite easy, especially if one does not live in the U.S.
Furthermore, a person born outside the United States may also be a U.S. citizen at birth if at least one parent is a U.S. citizen and has lived in the United States for a specified period.
The claim you made was that a person whose mother was born prematurely in the U.S. but did not reside there and the person never visited the U.S. was a U.S. citizen. I quoted that U.S. Code (the actual law) that specifies what that period is (6 months, 1 year or 5 years at least 2 of which were after the age of 14 depending on other factors). See this.
being born on a us plane in international air is seen by the irs as being born on us soil.
There is no mention of needing to claim citizenship, you just are.
You are just wrong.

From the U.S Department of State Foreign Affairs Manual:
a. Birth on U.S. Registered Vessel On High Seas or in the Exclusive Economic Zone: A U.S.-registered or documented ship on the high seas or in the exclusive economic zone is not considered to be part of the United States. Under the law of the sea, an Exclusive Economic Zone (EEZ) is a maritime zone over which a State has special rights over the exploration and use of natural resources. The EEZ extends up to 200 nautical miles from the coastal baseline. A child born on such a vessel does not acquire U.S. citizenship by reason of the place of birth (Lam Mow v. Nagle, 24 F.2d 316 (9th Cir., 1928)).

and

b. A U.S.-registered aircraft outside U.S. airspace is not considered to be part of U.S. territory. A child born on such an aircraft outside U.S. airspace does not acquire U.S. citizenship by reason of the place of birth.


So your first assumption is proven wrong, therefore rendering your whole argumentation moot.
Not an assumption, documented from the U.S. code and the Foreign Affairs Manual.
a few hundred people here have been refused a bank account this year. So it’s not some hypothetical point
Where is here? Are you claiming that a few hundred people who have never been to the U.S. but acquired U.S. citizenship by having a parent who was a U.S. citizen (by way of having been born in the U.S.) were refused service at all banks in your country because of this, or just that people who hold U.S. passports were refused service, or something else? Please provide some documentation for this statement.
 
No, they are paying the absolute minimum. And the 7% was just because the got a 13,5 billion fine from the EU. Which they are fighting.
Wrong as usual. The money for the fine has been put in escrow and is not counted as part of that 7%. They won the appeal, the EC has stated they plan to appeal, but at last count had not yet filed the paperwork to do so.
 
In otherwords the US company is paying the taxes of the other country (ie paying the EU) to get out of paying the IRS.
Actually, it does not get them out of paying U.S. taxes if they repatriate the money. The goal of paying in Ireland is to take advantage of the lower rates there, vs. other countries in Europe. Apple leaves the money overseas to prevent paying U.S. taxes on it, after already having paid taxes to the foreign governments. A successful part of the last tax reform act was to lower the tax rate on repatriated foreign earnings, to get more of that money back in to the U.S.
 
It's not enough you have streaming services were companies decide what you can/can't watch... Now it goes fuurther in EU ?

Governments know 'a deal' when they see one.
 
It could only have been Ireland, Apple isn’t a party in that dispute. Apple would have to pay, but the EU commission ordered Ireland to claw back 13,5bln from Apple.
It was Apple's money and per Ireland welcomes Apple tax bill ruling (1:04) "even if we hadn't Apple would have taken this case and Apple would have won the case today anyway." So Apple was a party in that dispute. Ireland just beat Apple to the appeal.
 
Actually, it does not get them out of paying U.S. taxes if they repatriate the money. The goal of paying in Ireland is to take advantage of the lower rates there, vs. other countries in Europe. Apple leaves the money overseas to prevent paying U.S. taxes on it, after already having paid taxes to the foreign governments. A successful part of the last tax reform act was to lower the tax rate on repatriated foreign earnings, to get more of that money back in to the U.S.
"Repatriate the money" and "leaves the money overseas" are the key points here...it is perfectly legal way for Apple (or another other US company) to avoid paying money to the IRS.

Sadly this and other happy perfectly legal little accounting shell games allow the totally screwy situation where a company can make billions and get a tax credit from the US government. (Activision Blizzard didn’t pay any taxes in 2018; Americans Paid $228 Million For Activision Blizzard’s Tax Credits In 2018)
 
"Repatriate the money" and "leaves the money overseas" are the key points here...it is perfectly legal way for Apple (or another other US company) to avoid paying money to the IRS.
Not repatriating the money saves the tax, being taxed by Ireland does not. If they are taxed by Ireland and still repatriate the money they are still taxed, hence my statement that their goals in having the revenue taxed in Ireland have nothing to do with their U.S. tax issues. 🙃
Sadly this and other happy perfectly legal little accounting shell games allow the totally screwy situation where a company can make billions and get a tax credit from the US government. (Activision Blizzard didn’t pay any taxes in 2018; Americans Paid $228 Million For Activision Blizzard’s Tax Credits In 2018)
I wish people would just understand that companies do not pay taxes, their customers, employees and shareholders do. From which of those pockets the money comes depends on the market. If there is low pricing pressure, customers will pay most of the tax, if there is higher pricing pressure, employees and shareholders will pay more of it. Just like the ”employer contribution” to Social Security. It is a fantasy to think that comes out of the employer’s pocket. Just like the employer’s health care costs, etc., these costs are all being paid by some person in the end. At least with benefits, it is clear they all come out of the employee’s pocket (it would be great if, for example, I could just get my employer’s contribution for my health care costs in cash, as I am covered by my spouse’s company’s plan). :)

While they are usually regressive, at least with sales taxes, who is paying is clear. They reason the EU wants a mandate like this is that it is a tax, ultimately paid by someone, that their citizens do not see as one. Their hope is that either it gets passed to citizens outside the EU or their subjects blame the streaming services for the subsequent price increase. I would be willing to bet that most people arguing for this mandate would oppose a much more clear and direct ”local content tax” that was only paid by EU residents and just went into a fund to subsidize content.
 
I'm against the EU on this unless of course the EU would like to spend the extra money for the content. Also I do not recall them doing this to Disney+
 
I'm against the EU on this unless of course the EU would like to spend the extra money for the content. Also I do not recall them doing this to Disney+
They plan to do this to everyone, the article only talks about AppleTV+ because it is the service about which the Irish Government Official complained first. Probably because talking about Apple generates the most headlines and since it is so small, least likely to generate negative consequences for him.
 
They plan to do this to everyone, the article only talks about AppleTV+ because it is the service about which the Irish Government Official complained first. Probably because talking about Apple generates the most headlines and since it is so small, least likely to generate negative consequences for him.
It is funny to have someone talk about a company worth US$2 trillion as "small". :)
 
It is funny to have someone talk about a company worth US$2 trillion as "small". :)
Should have been more clear, even though TV+ is small complaining about it is unlikely to generate a negative reaction as first threatening Disney+ or Netflix would.
 
They plan to do this to everyone, the article only talks about AppleTV+ because it is the service about which the Irish Government Official complained first. Probably because talking about Apple generates the most headlines and since it is so small, least likely to generate negative consequences for him.
Ah I didn’t know that and maybe I missed reading that part. I hope it doesn’t get to the point where let’s say for example a movie or TV show films on an island off coast in Maine or Canada and uses that as a backdrop for Ireland or Wales that the EU demands payout solely based on reference to the name of the country.
 
Register on MacRumors! This sidebar will go away, and you'll see fewer ads.