Thatâs great news for @bandage 's friend
Senile old git forgot the pin for the Escrow account already.
Good article in the Times today.
âDefinatelyâ.
Lolz
We are comparing a typo on an Internet forum to one on the main splash of his professional website.
Lolz.
Youâre more interested in a typo on a website than with dealing with the points the article makes.
Oh my, how unprofessional
Your man said this was a good article about Apple
How do you know that? I havenât said a word about the article, I just made comment on Peterâs professionalism.
Em, because you replied about a typo on a website rather than dealing with the points the article makes, pal.
Because I googled Peter firstly and it came up. Didnât say a word about the article pal.
You keep proving my point.
I havenât read the piece yet, when I do Iâll give you my thoughts on it.
Good or one you agree with ???
The guy is clearly an âEUâ type in his mindset. He doesnât deal with the actual tax issues which is fine in a sense that he is trying to talk about the EUâs competencies but is pretty key to being a thorough analysis of the issue.The worrying aspect of the ruling was its attempts to ride roughshot over OECD principles.
Unfortunately he loses quite a bit of credit there at the end by talking about Apple having a âprovisionâ in their accounts for these earnings. They have a provision for US Corporation Tax when these are remitted, This is a completely different kettle of fish to what he is suggesting. Apple have cash sitting there that they donât want to remit to the US org currently because of the US rules, they know they will pay something eventually so provide for it under standard accountancy practice. There is not one mention of a specific provision for the EU case, it is entirely for US CT as far as I can see;
The foreign provision for income taxes is based on foreign pre-tax earnings of $33.6 billion, $30.5 billion and $36.8 billion in 2014, 2013 and 2012, respectively. The Companyâs consolidated financial statements provide for any related tax liability on undistributed earnings that the Company does not intend to be indefinitely reinvested outside the U.S. Substantially all of the Companyâs undistributed international earnings intended to be indefinitely reinvested in operations outside the U.S. were generated by subsidiaries organized in Ireland, which has a statutory tax rate of 12.5%. As of September 27, 2014, U.S. income taxes have not been provided on a cumulative total of $69.7 billion of such earnings. The amount of unrecognized deferred tax liability related to these temporary differences is estimated to be approximately $23.3 billion.
Whilst his overall outlook on EU Policy is helpful the killer passage is wrong.
Nigel farage is a coward and a fucking idiot whoâs sole attribute is an ability to appeal to idiots. That bilge is devoid of both intelligence and meaning. Iâm surprised anybody bothered posting it.
Just look who posted it Flatty. Heâs the biggest fuckwit on here.
Biggest wum Iâd say. I hope.