A Tidal Wave of Corporate Migrants Seeking (Tax) Shelter | Hacker News Reader

A Tidal Wave of Corporate Migrants Seeking (Tax) Shelter

nytimes.com

50 pointshvo81 comments

The big problem is really the changes made to the US tax code during the Clinton era and continued by Bush and Obama. In particular, the ability of US companies to defer taxation on profits made abroad until they are repatriated. Effectively, these profits sit in limbo since they aren't taxable by the country in which they are 'made' (e.g Ireland) because they belong to a US company. Companies then apply pressure on politicians to announce tax amnesties that enable them to repatriate the profits with negligible tax.

Blaming all of the above on other countries by casting them as tax havens is a complete charade. The US could fix this problem today on its own if it wanted to. It just needs to get its house in order and e.g. get rid of the deferral rules. The best article I've read on the subject was here: http://www.rollingstone.com/politics/news/the-biggest-tax-sc...

Edit: Another good article on this is here: http://www.irisheconomy.ie/index.php/2016/01/22/upsetting-th...

It's a little bit more technical as it's written by an Irish economist for an audience of economists, but it's interesting in that it gives a good overview of the situation from an Irish perspective.

Ireland is regularly called a tax haven and comes under heavy scrutiny. It seems politically convenient for many of the bigger countries to point the finger rather than introduce their own reforms. Oddly often by places like the UK who happily operates the Channel Islands, Isle of Man and Jersey in the same manner. Irelands advertised rate is actually quite close to its effective rate which most other countries don't do. Belgium, where the official rate stands at 34% but this report said companies were handing over 6.5% on their profits. The truth is though if everywhere is partially a tax haven then no where is.

http://www.pwc.com/gx/en/paying-taxes/pdf/pwc-paying-taxes-2...

The Channel Islands and IoM are Crown Dependencies and not technically part of the main UK economy.

They live in a sweet constitutional loophole which gives them the right to set their own tax policies. Inevitably they're very different to those set by the British parliament for the mainland.

The British monarchy, which effectively administers them directly, through a small bureaucracy, apparently has no problem with this. Some of the population might have a problem with it, but it's never been allowed to become a political issue.

Much of the real - but unofficial - value of the UK economy comes from tax avoidance.

This partly explains why there's so much condescension here for manufacturing, software engineering, and start-ups: real entrepreneurs work in investment management, market trading, high-level deal-making and negotiation, and tax strategy.

They don't play with computers - that's something kids and engineers do.

Yet individuals with a US passport living in another country and not doing any commerce in the US are required to file and pay taxes in the US. The US is the only country (there may be one other small African nation) that taxes it's citizens abroad.

Giving up your citizenship is also no simple. The cost has gone form $300 to over $2400 and you need to pay taxes that are due 10 years back. The reason for giving up citizenship may also not be because of taxes.

it's been a long time that corporations have more rights than proper citizens in the us.

the aclu or some org used to have in the 90s several "challenges" for people that could apply corporate benefits to individuals in court. i don't think any prize for claimed ever. but I'm not recalling the correct program name to be sure

All unrealized capital gains are also taxed upon giving up citizenship. Furthermore, one still pays U.S. Estate taxes on what one has left upon death, no matter how many years in the past one gave up his or her citizenship. Currently, Federal estate tax is 40% (there is also state estate tax up to 20%).

You also are not allowed to spend too much time back in the US once you have relinquished citizenship without triggering US income taxes again.

How is it possible for the US to collect estate tax on a non-US citizen? Doesn't that go against international law? Once you are no longer a citizen that country has zero right to ask for anything.

Increasingly it isn't Ireland, but China or some other big economy where the money is made with their own incompatible taxation systems (you can deduct "foreign taxes paid" but not necessarily other cost of doing business fees that exist in lieu of taxes).

Effective double taxation is definitely possible when one tries to tax worldwide income, leading to a competitive disadvantage for American companies compared to their non-American competitors (e.g. IBM vs. SAP). So the US government introduces these loopholes to even the playing field, which are easily gamed and lead to abuses.

My understanding was that they do pay tax in the country that the profits are earned (unless of course the country has a 0% corporate tax rate), but that they don't pay tax in the parent company until they repatriate.

If that is the case then I'm fine with it. I'm obviously not fine with tax holidays / amnesties; but I consider that a different matter.

Well they do in theory, in practise of course they don't, and the end recipient country is usually Bermuda or somewhere, via other tax evasion schemes.

Because of different service and intellectual property agreements between different subsidiaries of the company, the subsidiaries almost never generate substancial (accounting) profit.

IMO, that's perfectly fair. E.g. Apple isn't generating profit in the UK; it's generating sales in the UK (which are taxed as all sales are), but most of its profit was generated in the US (design, research, strategy, innovation, ...). I think it's a huge problem that the US doesn't force companies to pay tax on profits.

That isn't exactly profit. As long as things are sold at realistic prices (ie, bulk iPhones are sold to the subsidiary at the same price they would be sold to a domestic buyer) then it should all be fine. It generally works out for multinationals headquartered in Canada, but granted there are far fewer tax loopholes here.

From the article, Johnson Controls is now a foreign-owned company, and consequently: 1. Cannot lobby the US government any more 2. Is not eligible for future bailouts 3. Could rightly be slapped with $150M/year of import duties to make a statement.

I have no problem with countries rewarding corporations for having substantive physical presence within their borders, and for putting external competitors at a financial disadvantage.

The US is a big place with an expensive military and social welfare program, and millions upon millions of sweet, delicious consumers. The US already runs a deficit, meaning there is insufficient tax revenue.

Corporations can make their own choices about whether the cost of doing business is worth it or not, but nobody who is transacting money should be exempt from making tax contributions to society, and certainly not at the scale corporations are.

The article identifies the problem, but the conclusion appears to be that we should win the race to the bottom by going straight down. If the USA adopts Ireland's tax code, what happens when another country goes even lower?

At some point other factors like ease of contract enforcement, infrastructure, etc. become more important than shaving off a few more percents from the taxes. So in the end it boils down to which government is able to provide better services for your buck which is how it should be.

If only physical persons could relocate to a better place with the same ease corporations do now the governments would suck so much less.

>If only physical persons could relocate to a better place with the same ease corporations do now the governments would suck so much less.

If physical persons could relocate to a different country with the same ease as corporations then the instability of their tax bases combined with the difficulty of ensuring compliance with their taxing regime might very well spell the end of nation states.

Global GDP would double if labour was allowed the same freedom of movement as capital.

But the human condition is such that I do not think it's not going to happen anytime soon :(

>Global GDP would double if labour was allowed the same freedom of movement as capital.

Really? And would global average wages double, or would the profit margins on ever-cheaper labor do all the growing?

Assuming inequality is constant - then yes. Your purchasing power would double, you could afford twice as much food, apple would produce twice as many ipads, etc.

>Assuming inequality is constant - then yes.

Variables rarely remain constant in the real world in the way that they do in ceteris paribus thought-experiments.

That creates a really significant free-rider problem. In your hypothetical, companies have a strong incentive to start in countries that have strong infrastructure and services (safety nets to reduce risk for founders and early employees, higher-education to ensure a supply of educated workers, etc), then move to a low-tax jurisdiction once they are successful.

Imagine if investors in startups couldn't take equity, but were limited to taking a percentage of current profits. That would create a huge disincentive to be an early-stage investor, and a huge incentive to be an investor that could come in with the cheapest rates at the last round of investment for a company that already had established growth and revenues.

In the alternate, consider the hypothetical of tax rate auctions at the time of birth. I.e. what tax rate would people bid in order to be born and try to become successful in the U.S. instead of somewhere else?

While that's true, holding everyone by force is the most primitive and inefficient (in terms of common good) solution I can think of. For example, the safety net is in fact an early stage investment so it would be logical if the government providing the safety net would take equity in exchange. In fact that's one of the reasons why safety nets aren't such a good idea. The government essentially becomes an angel fund that funds every single idea no matter how dumb. Can't imagine this bringing about an optimal outcome.

It doesn't create much of a free rider problem at all, actually. Most tax money is spent on wealth transfers to old people (and non-workers to a lesser extent) and the DoD. These are not particularly useful for startups.

If a company headquartered in Singapore makes use of US labor (and implicitly our effective, but extremely overpriced schools), it pays a fair rate of taxation on it. It simply doesn't have to pay taxes to the US on profits from selling goods manufactured in the Philippines to citizens of Japan.

That's ultimately the reason for moving corporate registration overseas, and that's the reason my next corporation will probably be headquartered in Singapore. Global taxation is insane; it's taxing US corporations for services that other governments have already provided and taxed them for.

If you had to roll the cosmic dice again, would you rather be born in Singapore or the United States?

The US is obviously a better place to grow up, since I avoided 2 years of slavery and the risk of execution for selling drugs. I also don't like malls very much and I'm vegetarian, so obviously Singapore won't be my favorite place to live.

What do these (non-economic benefits) have to do with efficient corporate tax rates or your claims about freeloading?

The value of growing up in the U.S. (or starting a business here) isn't measured by the economic value of services you receive directly. Most of the value is in the social order cultivated by the country's people and institutions. Even things like liberal social attitudes create value--you likely couldn't have started Facebook in a country that expects half the population to veil their faces. Forget about Tindr.

Indeed, even those wealth transfers to old people create economic value. Those wealth transfers still exist in countries without Social Security--they just happen "off the books" through familial relationships. And that has a lot of downside. The burden of caring for elderly parents disincentivizes young people from taking career risks and limits geographic mobility. Not to mention: try creating Tindr in a society where everyone lives with their elderly parents.

Being born in the U.S. (or Germany or a handful of other countries), has an enormous impact on your lifetime income, keeping everything else constant. That has intrinsic value.

Creating social order costs money. Benefiting from that social order up through the point you're successful, then taking that success--which society has invested in--to the lowest bidder tax jurisdiction is freeloading. That's why I presented the hypothetical about people bidding on tax rates at birth. Choice is fine and competition between countries is fine, but letting people and capital move freely after they've found out how everything turns out does not incentivize countries to create the conditions that maximize prosperity and opportunity. It incentivizes countries to poach successful people (and companies) from other places, after another country has put in the initial investment and taken the initial risk.

There is so much wrong with this comment that I don't even know where to start.

First, most of the benefits you describe (e.g., ample vegetarian food in NYC, very little in Singapore) are not paid for with taxes or provided by the government. The fact that the US govt happens to be the strongest bandit in a region where hookups are easy is not a justification for giving them profits earned by manufacturing goods in Bangladesh and selling them in Malaysia.

Second, if growing up/being born under the US/German social order were actually important, then there is a very easy way to measure it. Take people born outside this order but give them permission to work in global markets and compare their income to natives. Indian and Chinese immigrants tend to outperform Americans, which pretty much solidly refutes this claim.

Third, you seem to be conflating the purchase of services with equity investments. All your critiques of freeloading should apply equally if I build V1 of my software on AWS but switch to Softlayer for V2.

> The fact that the US govt happens to be the strongest bandit in a region where hookups are easy

The U.S. government, and the American public on behalf of who it spends tax money, did not just come along and take over an existing liberal productive society. It created that society. That society wouldn't exist without it.

> Second, if growing up/being born under the US/German social order were actually important, then there is a very easy way to measure it. Take people born outside this order but give them permission to work in global markets and compare their income to natives. Indian and Chinese immigrants tend to outperform Americans, which pretty much solidly refutes this claim.

The U.S. immigration system, by design, is very selective about which Indians and Chinese it allows to emigrate. Their performance says nothing about the value of growing up in the U.S. Besides that, your argument proves the opposite of your intended point. If there is no value to the U.S. besides the economic value of the government services people receive, why would the best and brightest from India and China struggle to come here to start their careers? Is it because of our fantastic public transit?

> Third, you seem to be conflating the purchase of services with equity investments. All your critiques of freeloading should apply equally if I build V1 of my software on AWS but switch to Softlayer for V2.

Amazon will charge you $X for AWS whether or not your product ever generates any revenue. The U.S. government's investment into education, infrastructure, and the social safety net will be there for you whether or not you succeed. It's much more like an equity investment than a simple exchange of services for money.

(Not OP)

> In your hypothetical, companies have a strong incentive to start in countries that have strong infrastructure and services (safety nets to reduce risk for founders and early employees, higher-education to ensure a supply of educated workers, etc), then move to a low-tax jurisdiction once they are successful.

In this hypothetical, governement will know that a company will migrate away once it find a better one. This will be reflected in how gov't will charge. It will probably mean the end to "% of income" based taxes instead fixed taxes.

Think of government as a corporation providing some services because that what it will be once movement and /citizenship/ becomes easy. The people who stay (i.e. actual citizens) will play the role of shareholders and (hopefully) will be more critical of their goverment.

Removing restrictions on immigration aren't a silver bullet. The opening of labor markets in the EU has caused much lower social mobility than previously expected (ie. many Greeks stayed in Greece even though they could get much better jobs in Germany).

Is there anything I can read up on this? I hear the population of Baltics halved, sounds like a rather drastic effect.

Although I didn't imply immigration restrictions are the only problem either- indeed the language and other cultural barriers as well as our tendency to form bonds that are painful to break all work against mobility.

This article has quite a few sources: http://www.migrationpolicy.org/article/free-movement-europe-... And a more recent report: http://ec.europa.eu/social/BlobServlet?docId=11945&langId=en

Another solution is to move from taxing profits to taxing consumption, i.e. through VAT, and then enforce it even for virtual services. That way, Apple's US tax would for example be proportional its US sales, which sounds fair.

That pushes people to buy goods and services overseas. AKA, why buy a US yacht and pay an extra 20%.

The real solution IMO is to tax US companies for world wide profits and have punitive taxes on foreign companies to keep US companies from pretending to move offshore.

If I as a US Citizen were to work overseas, I would owe US tax on the wages I make outside the country. Why doesn't the same logic apply for a company that makes profits overseas? This is a rhetorical question, obviously, we all know why the system is stacked in favor of corporations.

I am a US citizen who works overseas. You get to deduct your foreign tax obligations on your US tax returns (if you don't go for the standard foreign income earned deduction). Oh, well, some "taxes" aren't really taxes in the US sense, like taxes on health insurance, or what about social security contributions? And then there are weird situations where a US citizen goes on a business trip in the US and is on the hook for both Chinese and US taxes.

Believe me, US citizens working abroad and US companies doing business abroad suffer through similar pain when it comes time to file tax returns. Resolving differences in two completely different systems is very hard.

You mean close the economy to foreign companies ala North Korea? I'm not sure that is a nice way to go, definitely not WTO friendly.

No, more like disqualify them for specific tax breaks, or slightly increase there tax rate ~1-5%. Don't forget China for example is very hard on foreign corporations, yet they are generally happy to jump though hoops for such a large market.

Yes, they are, being a US citizen working in China I know that very personally. So if the US goes the China approach, we only welcome foreign companies that we can screw something from, like IP or expertise, and block the rest out (foreign social networking websites? create a great firewall).

The US benefits GREATLY from its open market while China's semi closed market in turn hurts it a lot. Ya, foreign companies still operate there, but only with an expectation that it will open in the future, not given today's situation!

Having a different tax rate for foreign companies would basically destroy the WTO, all those treaties that benefit the USA in lopsided ways go away, and we will just lose a lot of wealth in one swoop. All the other countries will retaliate of course, taking a significant chunk of global GDP that relates to trade down, almost probably causing a few wars and such.

Your vastly overstating things. All countries including the US already favor local industry's. Just look at the taxes on sugar.

PS: In a wider context, the benefits of free trade are overstated. Not all industries have equal long term benefits even if the short term looks great. https://en.wikipedia.org/wiki/Phosphate_mining_in_Nauru

The problem of Nauru presents a paradox. The striking contrast is between a superficially happy state of affairs and an uncertain and indeed alarming future... But this picture of peace and well-being and security is deceptive. Indeed it is a false paradise. For these gentle people are dominated by the knowledge that the present happy state of affairs cannot continue. (1962)

The benefits of free trade are of course lopsided in the USA's favor. But the whole world gets a boost anyways, especially Nauru who can't produce much locally. If America was left to its own market, there would be no Boeing or Silicon Valley to speak of.

Ya, we could go back to local production, isn't that what North Korean juche is all about?

VAT is, unfortunately, a flat tax. Moving to a VAT-only system without any offsets would be the biggest redistribution of wealth (upwards) since the Bush tax cuts.

VAT isn't flat. Since it does not apply to monetary instruments, a VAT is regressive.

I still think that VAT with offsets is the best taxation form available (and universal income the best offset form). But it alone is disastrous.

And, while we are at it, make sure the VAT is really a VAT, not a sale-value tax. Because it usually is, and it's the one tax form worse than a VAT.

VAT is one of the worst possible solutions. The ones who carry most of the tax burden are usually the consumers, through higher prices (though it depends on the nature of the good). VAT is one of the most discriminating taxes out there, where the poor pay relatively speaking much more tax than the rich - because consumption doesn't increase linearly with wealth.

> Apple's US tax would for example be proportional its US sales, which sounds fair.

Apple's US tax already is proportional to its US sales. The major strategy that it and other US tech companies use is keeping overseas profits off-shore, not avoiding taxes on US sales.

Personally, I don't think the income tax for corporate entities makes sense. The scale and complexity of these organizations makes compliance and enforcement ridiculously expensive and unfair.

Most famously, General Electric has hundreds or low thousands of IRS employees on-site performing audit functions continuously. It's a waste of everyone's time.

IMO, it makes more sense to apply excise taxes, consumption taxes or taxes on corporate treasury balances. Or not to tax them at all.

> Or not to tax them at all.

Agreed. I challenge anyone who complained that Congress should not have 'default' back in 2013 (in other words, continue to issue debt forever) to explain why the tax rate ought to be nonzero? I mean, if people continue to purchase Federal bonds, why tax corporations (or anyone)?

If you want to tax people and corporations to 'reduce inequality', consider your position on fairness...

Because corporations use _and require_ a disproportionate amount of government regulatory protection/oversight and bureaucracy, as well as government spending.

For example, our navy is mighty and far-flung across the globe, and it's not because we're proud of our maritime traditions but because the force of the US Navy ensures stability for commerce.

The average American benefits to a small degree from this international commerce, but the corporations (and by extension the wealthy who own the corporations) benefit far more. This is why we have progressive taxation schemes where the wealthy pay more, at more levels. Or they're supposed to, at least.

If this is true, lets just levy an international shipping tax on goods shipped under the protection of the US Navy. Anyone who doesn't pay their (purely voluntary) Navy tax will also be left to the pirates if that situation arises.

This tax will then be added to the cost of shipped goods.

If the wealthy are actually the people consuming those shipped goods, then they will in fact be the ones to pay. If you are wrong, and the primary beneficiaries of international trade are actually middle class consumers, then middle class consumers will pay.

The military cannot be a transactional service, no more than the justice system can be. It's in our national interest to be protected against the aggression of other nation states.

My original point was that we have a system today where a significant portion of the economy is devoted to calculating taxes. I'm not saying don't tax corporations. I'm saying tax corporations on a basis that can be enforced in a reasonable way.

Indeed, in general it strikes me as a good principle to align risk with benefit (skin in the game).

I don't really care about equality in this context. That's a different problem for a different day.

I do care about the overall integrity of the system. The notion that my uncle's carwash probably pays more in income tax than General Electric undermines the integrity of the system as a whole.

reduce corporate tax by half and introduce revenue tax of 0.5% ?

If the USA adopted Ireland's tax code then companies would have to pay 12.5% on trading income. The reason Ireland is a good place for American companies is because of a loophole called the Double Irish. Basically Irish based companies pay tax where they are originally registered and in Delaware the code stipulates that taxes get paid where the revenue was generated. That means the US expects the companies to pay the tax in Ireland and the Irish expect the companies to pay the tax in the US. Therefore the potential tax payment ends up in no-mans land and never gets paid whilst remaining all perfectly legal.

Double Irish is virtually finished -- your information is outdated. Only a select number of companies can avail of it that had already done so and it's being phased out and will be completely gone by 2020.

It is what brought all the big tech companies to Ireland in the first place but yes it is being phased out. The latest seems to be another loophole where companies register a subsidiary as tax resident in an actual 0% tax haven and then pay royalties to said subsidiary. This gives them zero profit and therefore zero taxable income but there is very little Ireland can do about without shooting itself in the foot (such as taxing revenue and ensuring Apple et al close up shop and take their business elsewhere).

If they decide to be tax resident in Ireland the 12.5% corporation tax is hardly a 'tax haven' but it's still better than most. Another big draw is the amount of money the Irish government puts up to attract FDI through their Industrial Development Authority (IDA).

It isn't a race to the bottom. The U.S. can have a 0% business tax rate and still have plenty of tax receipts.

Wouldn't it be better to reign in these oligarchies that are hell bent on controlling the world and pushing our (The U.S.) standard of living further down? This myth of free trade is clouding the picture. 38% of all world trade is inter-firm trade and should not be considered real "trade" anyway, according to Alfred E. Eckes, former chairman of the U.S. International Trade Commission.

"Ultimately, the only way inversions will stop is when the corporate tax code changes so it becomes more attractive for American companies to be American companies."

Or it becomes too expensive for them to not be American companies. After all, the US is a huge market that everyone wants a piece of.

A huge open market that allows foreign companies to operate in and pay taxes (just not on worldwide income).

You already pay taxes for profits in the US market. What they're wrangling over is paying US taxes for income generated in other markets.

I'm not sure why any corporation would want to be headquartered in the US.

Could always go the China/India route of basically not letting foreign companies do business in the country without some sort of joint venture in place....

I'm not recommending this path of action.

Then why are so many companies headquartered here? I'm legitimately asking.

It's pretty easy to incorporate in the US and if your primary market is here there's not much point to incorporating elsewhere (you won't save on US taxes).

It may just be that they started as fully US companies. You wouldn't incorporate in Ireland for your two person US garage company. Particularly in, say, 1950.

The U.S. is no longer so important that it can have uncompetitive policies and still come out on top.

We should be the tax haven.

350 million people, almost all of them speaking the same language, unprecedented business transportation infrastructure, high amounts of disposable income among the top 20%, and the weakest labour rights in the developed world?

How can you possibly claim that the US is no longer important?

Why is it corporations only pay taxes in one country anyway? That seems paradoxical, if they're selling goods in multiple countries then they must be using the infrastructure of all those countries, and isn't that one of the big reasons we have taxes in the first place?

> Why is it corporations only pay taxes in one country anyway?

They don't. They pay taxes in pretty much every country where they operate. Pfizer may move to Ireland, but they'll still pay US taxes on their operations in the US.

Well yeah but clearly the tax savings are enough to justify the expense of the legal time behind it and the logistics/admin overhead of the move, they wouldn't be doing it if it left them in the red.

Sort of, these companies generally have not been bringing cash back to the US any way, so they haven't been paying US taxes on their non-US money anyway.

What moving to Ireland will allow Pfizer to do is pay dividends out of their non-US cash without paying US taxes.

Why do we care if a company is nominally American or not? It just seems odd. Nominally being Irish or Swiss does not mean a majority of your employees are in those countries.

Who will these companies hire when they move to Ireland? There was a mass emigration last year where, at its peak, 10,000 people were leaving per week. It sucks living in a country that is rainy and overcast most of the year, how can you convince someone from a sunny and warm state to move there?

I just feel like something is missing when I hear things like "X company is moving 500 jobs to Ireland". Where the hell are they finding these people? They country has a population of 6.3mil!

Ireland is in the EU, so people from all over the EU can move there to work. For the recently joined countries in eastern Europe it's caused a dramatic brain drain.

Keep in mind, their headquarters is located in Ireland but they can still do operations in the United States. This is a strategic move to avoid U.S. taxes on profits made outside the country. The United States is one of the only countries in the world that taxes outside its boarders. They will save on foreign profits, but they will still pay taxes on their U.S. income... I find it ironic that our politicians promise jobs, but aren't willing to reduce taxes and regulation on businesses. Then, they get upset when businesses want to leave. What's their solution to fix this? "tax them more for trying to leave" -__-

Any amount of taxes is too high for these businesses.

Lowering taxes, because of taxation arbitrage is a quick race to the bottom.

But corporate US taxes are on profits, so if the US only taxed inside the country, you can lower your US taxes by engineering your organization such that you can claim US operations pay your business unit that resides in a different country amounts that are similar to your US profits.

So imagine a company that sell 500m of a product in the US and today has costs of $400, with $100m in profit. If they have to pay the business unit in Ireland $90m for their voodoo design expertise, then the company still has 100m in profit, but now only 10m will be taxed in the US.

It's not as if consumption taxes lack loopholes themselves: In my own case, I spend about 20% of my earnings, with the rest going to taxes and savings (I am aiming for early retirement). So why would I spend my retirement years at a place wth a high consumption tax? The one way around that would be to start taxing money transfers across borders, and we all know that isn't happening.

They are unlikely to hire people in Ireland, they will have a postal address and probably little else.

Actually many large American tech companies employ significant amount of people in Ireland, Google, IBM, Intel, Microsoft each employ thousands of people.

> They country has a population of 6.3mil!

The population of Ireland is about 4.5 million. If you include Northern Ireland it's about the 6 million.

I'll agree with you on the weather part but it seems that it's not a deal breaker for many people. Ireland has a huge amount of highly skilled people ready and willing to work. People come and go all the time. The Irish government invested heavily in STEM education for 2nd and 3rd level students in the 90's and 00's. Emigration and immigration are as big a part of Irish history as the potato. Also many foreigners come to work in Ireland all the time. During the boom years hundreds of thousands of people from all over the world came to work in Ireland and seemed to like it. Added to that, in most places in the world people don't have the entitled mentality to work that is rife in SV where it seems to be a sellers market for jobs.

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