Hacker News Reader

Comment by trevyn | Hacker News Reader

It's money that they've made overseas from selling products through their foreign retail and wholesale divisions, so they didn't really "send it out."

View on HN

Actually, we're talking about money companies have ascribed to overseas operations, sometimes because that's actually where they do traditional manufacturing and sales ... and sometimes because they've created the darnedest shell companies to make it seem as if they're earning all their profits in Luxembourg, Ireland, the Bahamas or other tax havens.

Jesse Drucker wrote a lot about such tax maneuvers during his years at Bloomberg News. An overall link to his work is here: https://www.bloomberg.com/authors/APuiS-bL1Fc/jesse-drucker

Bullshit. This is not money that has been "earned" overseas. Its money that has been earned in the US but put on the book as overseas income.

That would actually be tax evasion, and it's illegal. There is no evidence for your assertion.

What actually happens is Apple sells product to international subsidiaries to sell in their countries. In some cases international subsidiaries build products and sell them to Apple US and other subsidiaries.

The profits from international sales and production are profits in the subsidiaries that sold or made them. They aren't taxable in the US until those subsidiaries pay dividends to their owner, Apple US. Given that the US and California corporate income tax rates combine to equal 40%+, Apple US chooses not to take dividends from the subsidiaries at this time, and allows the profits to accumulate in savings accounts overseas.*

*this is a simplification of course, but basically accurate. One thing Apple does is funnel lots of the subsidiary profits to Apple Ireland, because Ireland's tax rates for the bank account interest is extremely low. But it all works out the same as Apple Ireland is a subsidiary of Apple US, and Apple US can't touch those profits without losing over 40% of them to US/CA taxes.

You can talk about how that would be tax evasion and it would be illegal but in practical terms that is exactly what they are doing.

They just have hired a bunch of lawyers to tell them how to do it so that it is legal.

By the way, when you talk about selling product to international subsidiaries you are actually talking about putting their IP ownership in international subsidiaries and then having the American subsidiary pay licensing fees so that no profit is made in the US.

If it were that easy everyone would do it.

They are

Where are the money they made in the US then?

.. in the US. Probably paid out in dividends and salaries.

Currently Apple pays around $12B a year in dividends. It has averaged over $10B a year the last 5 years or so.

It's expected if a repatriation bill passes, Apple will pay out a special one time dividend to shareholders, and some think it will be as big as $100B.

And invested by Blackburn or whatever the Nevada corp is...Google it.

It's called Braeburn, a type of apple.

So they have 246B + US hoard?

No, they have $246B minus around $80B in debt. Some of the $246B is overseas.

Yeah so it's not money made overseas which was the original claim I was asking about.

Apple have famously not paid out much dividend though.

Whoever down votes will you please explain exactly where I am wrong here?

Making a series false statements without references.

What series of false statements?

Look back at your statements.

Yes whats the long series of wrong statements? By all means please correct me.

Nobody wants to bother, since you can check them easily yourself with google. That's why you are being downvoted without explanation.

Whats up with the attitude?

Asking a genuine question is not reason for downvote.

You are asking other people to do work for you that you could easily do yourself.

Rather than letting obviously wrong statements stand unchallenged people just downvote them. There is no obligation to explain.

A question is a wrong statement? Nice try.

Your questions contained implicit statements just like this one:

Why can't you stop spreading falsehoods?

Either way - you asked why you were downvoted, and now you have an answer.

In other words you can't point to any series of false statements so instead you just make things up.

Got it thanks.

https://news.ycombinator.com/item?id=14122276

There you go. So even your claim that I'm making things up is false.

Intellectual honesty is a currency around here.

What does that link prove? By all means.

Reply on news.ycombinator.com