So the issue here is that in the case of google or any major tech company investors + company only pay the 15% + marginal effective rate of 1 or 2% which is only 17%.
So the issue here is that in the case of google or any major tech company investors + company only pay the 15% + marginal effective rate of 1 or 2% which is only 17%.
Yes, many companies use complex tax structures to avoid paying US corporate income taxes on non-US profits. So what? They don't consume any US government services either, and Fred Wilson paid appropriate taxes to whatever nation Twitter Europe lives in.
Similarly, my employees (all located here in India) don't pay any US income taxes. Is there some reason they should?
GE paid a negative percentage of taxes because they lost money in prior years and used a loss carryforward.
The loss carryforward is a necessary hack to the system to prevent taxation from penalizing businesses with volatile income streams. Consider two investments - one makes $10 with P=1. Another makes +$60 with P=0.5, $-40 with $P=0.5. Without the loss carryforward, the volatile company would pay an average tax rate of 45% (15% of $60 when they make money, 0% of -$40 when they lose money).
Google, and of course virtually every multi-national corporation based in the US, does make use of many US government capabilities. I don't think it makes any sense to say:
>They don't consume any US government services either
However, I do think the corporate income tax issue is a subtle one.
It'd be interesting to compare what Larry and Sergey will pay in taxes versus government outlays for the things that have made Google possible.
These sorts of arguments always bother me because they over simplify the complexities of how one benefits from a public good or service. One example would be that Google doesn't have to worry about their engineers getting into a car crash on the way to work because the governments (federal and state) collectively spend billions of dollars ensuring that our roadways are safe for vehicles.
Another example would be that google doesn't have to spend money hiring private militaries or police forces to enforce their contracts because we have a judicial system that is paid for by the tax payers. This particular example is where your "consumption" argument falls down rather directly. Although it's true that they hire their own counsel, they are not the ones paying the salaries of all the various court officials. They "consume" these resources but in many peoples minds, myself included, do not pay their fair share.
>Similarly, my employees (all located here in India) don't pay any US income taxes. Is there some reason they should?
Of course not. The company that you set up and domiciled in America pays income taxes on the profit that you generate. Profit is usually defined as revenue minus expenses. Taxes paid in other countries are considered expenses and as such are accounted for.
>The loss carryforward is a necessary hack to the system to prevent taxation from penalizing businesses with volatile income streams.
Although we can both agree that GE's tax situation is very complex the problems that I and others have is that they directly lobby the government to get these tax incentives. The example I am thinking of is their lobbying arm advocating for an increased depreciation schedule on some of their capital equipment. This isn't fair.
The summary of my problem with your argument is that you benefit from all the things that America provides (government services, easy access to higher education, educated working class, pro-business climate, etc) but don't think that you should have to pay for any of this because "you didn't consume it." Just by living in America and being able to take advantage of these things you have consumed these things and you should have to pay your fair share. Consumption doesn't necessarily mean somebody handing you a check or waiting in a welfare line.
Is the Guinness Brewing Company or Tata similarly obligated to do business in the US just so the US government can tax them? And on the flip side, is GM obligated to do business in India so that India can tax them?
Given the billions of dollars that is building up in parking spaces overseas for major tech companies such as Google indicates to me here that the motivation isn't to re-invest in business overseas but to wait patiently for a tax holiday and repatriate the capital at next to tax free. And this is what I disagree with.
We can come up with all sorts of points and counter points about why our particular positions are correct but my issue is as follows:
1. I suppose that Google has built all these complicated transfer pricing agreements so that they can accumulate capital with out being taxed and wait for a tax holiday to repatriate the capital at next to no cost.
If 1 is true then I believe that this is wrong and Google is not paying their fair share.
Which part of this do you disagree with?
I disagree - I believe taxes are payment for government services received. Google Ireland and the Guinness Brewing Company did not receive government services from the US, and hence their "fair share" (to the US) is precisely $0.
Incidentally, the shareholders of Google USA may not live in the US. And similarly, the shareholders of Guinness may be located in the US. If it turns out that some large fraction of Guinness shareholders live in the US, should Guinness start paying taxes in the US for it's Irish operations?
(Guinness does, of course, pay taxes in the US for profits made by it's US subsidiary.)
So it's not so much about forcing truly international companies to pay taxes in the US (though they should pay taxes if they are indeed subsidiaries making money from the work of a parent company when that parent company repatriates profits), it's more about exposing the legal-by-letter-but-not-by-spirit practices of companies that hide money generated in the US overseas.
See http://www.npr.org/2011/03/17/134619750/how-offshore-tax-hav...
Where do you think that "the governments" got that money?
This applies only to Google USA. Google USA pays US income tax. Google India does not pay US income tax and does not receive these benefits.
The summary of my problem with your argument is that you benefit from all the things that America provides (government services, easy access to higher education, educated working class, pro-business climate, etc) but don't think that you should have to pay for any of this because "you didn't consume it."
My employees were educated mostly here: http://www.nifdpune.co.in/ and here http://www.softpune.com/index.shtml. I didn't ask where my devs went to school, but it was probably an IIT. Explain again how I'm consuming US government services?
We might get enough offsets in jobs, payroll taxes, etc to offset the corp taxes lost.
And better yet it does skew certain manufacturing concerns to not out-source but in-source..