Tag Archives: Inversion

#CookvTait principle has created problems for Apple and has created advantages for non-US persons and corporations

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Introduction …

The U.S. tax system is premised on the assumption that it can levy taxes on economic activity in other nations. This simple premise applies to both corporations and to individuals.

In the case of individuals: The taxation of economic activity in other nations takes place at the time that the money is earned.

In the case of corporations: The taxation of the economic activity, the taxation takes place when the money is returned to America.

In any case, the United States discriminates very strongly and punitively against all things American. The views of Apple CEO Tim Cook has some interesting comments on this issue.

Apple CEO Tim Cook interviewed on 60 Minutes 2015 …

”This is a tax code, Charlie, that was made for the industrial age, not the digital age,” he said. “It’s backwards. It’s awful for America. It should have been fixed many years ago. It’s past time to get it done.”

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Washington likely to keep close watch on tax loophole as Burger King seeks to become Canadian

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https://twitter.com/USCitizenAbroad/status/504576683551105024

Once again President Obama demonstrates his contempt for the law by noting that if he doesn’t like the results of the law, he has no respect for the law.

And on the Levin front:

Ohio Senator Sherrod Brown urged people to boycott Burger King over its move to relocate to Canada and eat at rival Wendy’s or White Castle instead. Meanwhile, Senator Carl Levin said he believes Burger King risks a backlash from its customers that would outweigh any tax benefit.

Of course, the U.S. could simply amend it’s tax laws to make them compatible with the rest of the world (that is if there is world outside the U.S.)

Financial Post | Business

MONTREAL • Corporate America is making a mad rush to the exits in a bid to lower its tax bill. But experts say the odds of political intervention in the stampede have increased as a result of a U.S. burger icon’s plans to become Canadian.

U.S.-based Burger King Worldwide Inc. has confirmed it is in talks to take over Canadian doughnut and coffee maker Tim Hortons Inc. The new company would be headquartered in Canada, making Burger King the latest U.S. company wanting to relocate to a lower-tax jurisdiction through a so-called inversion strategy.

My attitude is, I don’t care if it’s legal. It’s wrong

It’s an issue that’s gotten enormous attention in the United States. “They’re declaring they’re based someplace else even though most of their operations are here,” U.S. President Barack Obama said of the trend in July. “My attitude is, I don’t care if it’s legal. It’s…

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