I must say Iām enjoying this ding dong battle about Apple and itās taxes even though I havenāt a fucking clue who is right or wrong.
Itās like a debate on Ulster Football but in this instance the people involved seem to know what theyāre talking about
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And they are remaining civil, by and large
Have there been no holocaust denier accusations thrown out yet?
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They are both wrong
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Which makes it right
Has anyone ever been right on here?
[quote=āTim_Riggins, post:1427, topic:20334, full:trueā]
Christ you donāt understand you pay most taxes in arrears do you? 
[/quote]
I understand perfectly Tim. You would swear we were talking about Boeing or Caterpillar who take six months to a year to build a product. When you walk into an Apple store and buy an iPhone, itās booked as a sale. Apple would know their sales, operating profit and estimated tax on a monthly basis. Corporations, in the US at least, estimate their taxes and pay them quarterly. I think Apple would have a fair idea of how fast they were growing and what their estimated tax bill is. In the context of the above, timing does not even come close to explaining the discrepancy between taxes provided for and actually paid, for 2009, 2010 and 2010.
What did Apple pay to the US Treasury in 2012?
Apple FY 2017 Q2
Cash paid for income taxes: 6,878 bn
Quarter 1 tax provision: 6,289 bn
Apple FY 2017 Q1
Cash paid for income taxes: 3,510 bn
Quarter 4 FY 2016 provision: 3,482 bn
Apple are not paying out real time tax figures quarter by quarter.
They arenāt handing over cash that they donāt need to, you thinking it is so easy to determine is a fallacy. The IRS only closed out their audits of their 2012 taxes in 2016.
To express this in another way, letās look at the growth in their deferred tax over the last few years which is where they claim they hide the taxes they declare versus what they actually pay. In 2011 they had a liability of 6 billion and this year nearly 22 billion. That is quite the jump, 16 billion, and would make you think your assertion is correct on the amount they actually pay versus provision. But in that time they provided for 84 billion in taxes. That increase is there about 19% of the declared provision for tax unpaid, take a simple calculation and that cuts off about 5% of the āeffectiveā tax rate of around 25% Apple pay annually, bringing us back to the magic 20% which is around what we see when we follow the cash flows.
thereās a right ruck developing here
Two master debaters going toe to toe.
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A row about accounts on a sports website. Where else would you get it.
You are still not addressing the central question Tim, and your avoidance of the central issue confirms what I said in my earlier response regarding you having a vested interest in defending Apple. Clinging to what Apple report as evidence of what they actually pay in taxes (as opposed to what they pay plus they accrue for future potential tax liabilities) is like a drowning man clinging to a straw.
Read the attached article from the distinguished economist and tax reform expert Martin A. Sullivan and educate yourself on how Apple and (some) other tech companies operate. In short, what Apple do is take advantage of flexible accounting rules to do the opposite of most US companies. Under GAAP rules companies do not have to book tax liability on foreign earnings if they deem the foreign earnings to be permanently invested outside the US. In 2011 Apple deemed 57% of itās foreign earnings as not permanently invested and accrued a tax liability of $8.9B (an estimated 28.8% tax rate if the profits were repatriated). According to Sullivan, Appleās adjusted effective tax rate would be 12.8% if they reported like most other companies.
For Apple to claim their foreign earnings are not permanently invested outside the US is clearly ludicrous, given they have stated themselves they wonāt repatriate it unless they get favorable tax treatment.
this is proper fucking debating
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Labane, you are gone backwards here.
I have always stated that there was an amount of foreign earnings not provided for. Why are you posting this article? That is simply desperate deflection.
I have never denied that Apple avoid taxes. I never claimed it was morally right. I criticised the double Irish. I have been steadfast in saying that Apple should pay all of their CT in the US, as that is where it is owed, not Ireland. I donāt think it is ethically right that Apple shore up billions offshore and earn interest/provide bonds that make money on a cash pile some of which the US government should be getting.
However that is not relevant to the point on actual payments in tax. I merely stated it as some people will swallow hole this BS that X donāt pay any tax at all or these low headline figures. It is factually wrong, usually written by arts graduates workings for the New York Times and the Irish Times. Or politicians.
I also stated that this is all priced in my investors already. That is why the Apple share price took barely a peep after the EU announcement, investors read these things. It doesnāt make it ethically correct, I just pointed out that some of this unearned ābenefitā has been priced in already by shareholders.
This is incorrect. Anyone who actually invests and understands balance sheets, profit and losses and cash flows can get this from their financial statements. Apple provide a supplementary disclosure on their cash flows for tax. We have the movements in the balance sheet and we have the profit and loss figures. What it clearly shows is that Apple pays out effectively 20% to the various tax authorities they are required to for income tax, about 5% below that the headline rate.
Here are some of your other statements which you yourself have rubbished through further throwing info at the wall in here.
Incorrect. They avoid lots of taxes. but not all. as the article you link states.
The below is you stating that they provide for all taxes abroad and just donāt pay, and then several posts later you contradict yourself.
When confronted with the actual figures, from review of years of financial reports, this is your response;
So you happily quote some of their 10k reports, and say the others are tosh. This is moving the goal posts wherever you like and just ignoring certain facts to suit yourself.
We may have to move this to the boxing thread shortly
So, you didnāt read that article either, nor the Senate committee report, and have now resorted to a @Sidney, @sidney_waddell, @Sid_Waddell style argument of trolling though days of posts to make mainly semantic arguments. Are yourself and Sid the same person? Arts graduates and politicians? Martin A. Sullivan is possibly the foremost expert on international tax (other than the guys working for Apple obviously), Iāll take his word over yours (and mine) if you donāt mind.
We are actually in agreement on most points, except for your ludicrous claim that Apple pay their fair share of tax. The main issue I have is this bullshit from Apple that they pay an effective tax rate of 26%, setting themselves up as some kind of socially responsible corporation.
Letās so the math and look at how Apple would look if (A) they reported like most other US corporations, and (B) if they reported 100% of their global profit in the US where it belongs.
(A) Normal GAAP reporting, which allows no tax liability on foreign profit if it is invested abroad indefinitely. For 2012, the estimated $3.9B of booked tax liability for foreign profits goes away, reducing the effective tax rate to 12.8% (as Sullivan explains). The stated 26% is bullshit, itās taking advantage of flexible accounting rules to try and look good.
(B) If all pre-tax profit was taxed in the US, as it should be, they would have paid at least 40% between federal and state (state taxes are very high in CA*, although they are treated as a business expense for tax purposes). Thatās almost $29B on their $72.5B of pre-tax income in 2015. According to their 2016 10-K, they paid $10.4B tax in 2016.
So, in conclusion, they get the best of both worlds. They get to pay a third of the tax they should (ethically) be paying, and declare themselves as great lads for paying an 26% effective tax, when itās closer to 10%.
- CA tax for C-corps is almost 9%. Thatās a lot of the tax paid you see on their cash flow statement.
Christ. I read the article. You literally just posted an article about Apple dodging tax, well duh, we all knew that. When was that denied?
I simply have a figure of what they paid and that is the debate.
Where did I ever say that is āfairā? Please quote that?
Donāt twist things and make things up.
_Letās so the math and look at how Apple would look if (A) they reported like most other US corporations, and (B) if they reported 100% of their global profit in the US where it belongs. _
_(A) Normal GAAP reporting, which allows no tax liability on foreign profit if it is invested abroad indefinitely. For 2012, the estimated $3.9B of booked tax liability for foreign profits goes away, reducing the effective tax rate to 12.8% (as Sullivan explains). The stated 26% is bullshit, itās taking advantage of flexible accounting rules to try and look good. _
(B) If all pre-tax profit was taxed in the US, as it should be, they would have paid at least 40% between federal and state (state taxes are very high in CA, although they are treated as a business expense for tax purposes). Thatās almost $29B on their $72.5B of pre-tax income in 2015. According to their 2016 10-K, they paid $10.4B tax in 2016.
So, in conclusion, they get the best of both worlds. They get to pay a third of the tax they should (ethically) be paying, and declare themselves as great lads for paying an 26% effective tax, when itās closer to 10%.
You are all over the place here.
You have contradicted yourself so many times itās hard to keep up. One minute you claim all Appleās offshore earnings are within that 25% and that itās just a dodge. Then you flip flop the other way.
These are the facts. Apple record all of their income on their 10k. Within the 25% tax provision is some of the foreign earnings, whilst in the remaining 75% we have the accumulated 110 billion cash pile indefinitely invested.
So once again, letās look at several years of annual reports, and no hone in one one year which is a fatally flawed way of looking at a rapidly growing business. So lets take 5 years and the majority of the period youāre taking about.
That is a total provision for taxes of 58,377 bn from 2009-2014 provided for by Apple.
Based on a total pre tax profit for those years of 220,658 bn that is an average of 26.5%.
The deferred tax, which keep saying is where they squirrel away the provision on the balance sheet went as follows;
End of 2014;
Thatās a liability of 15,128 billion.
The opening balance at the 1st of their 2009 financial year was 910m (asset).
Therefore the movement in deferred taxation was 16,038 billion.
Subtract this movement from the provision and you are left with 42,399 billion in monies paid over.
Based on profits of the above of 220 billion that is 19%. Iāll grant you not our 20%, but as I pointed out time and time again there is also over a billion per year in equity stocks costs, hundreds of millions in US payroll taxes and other worldwide taxes on businesses. Hence my original statement;
No where did I say they pay their fair share, youāve made that up, once again. I simply said that this meme that Apple donāt pay tax is a lie.
Documents and exhibits and everything.
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A lot if effort being put in here to win this battle of the joyless dullards
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