tech companies have 89 billion in taxes offshore

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Fern

Elite Member
Sep 30, 2003
26,907
174
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Why couldn't a foreign company make a 0% loan to a US-based business that happened to be owned by the same parent corporation?

Section 7872 of the the US tax code says no below FMV interest rate loans allowed.

http://www.law.cornell.edu/uscode/text/26/7872

I can't guarantee it would apply, but I glanced at the law and don't see any exception(s) that would appear to apply.

While I won't research it, I'd guess such a transaction would be reclassed as repartiation of foreign profits and be subject to (US) income taxation. The point of the law is for non US subsidiaries to be able to keep needed capital abroad to compete. If they can loan it back to the US company they clearly didn't need it for operations abroad.

Fern
 

piasabird

Lifer
Feb 6, 2002
17,168
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When you file your taxes do you take exemptions and the credits available by law like charitable donations and exemptions for Housing Interest and Real estate taxes? Same thing. The truth is that almost all computer tech is built in places like Taiwan and Mainland China. We could put a tariff on all computer and phone hardware but then it would just cost us all more. The same could be said for automobiles. Many parts are manufactured overseas. Even airplane parts are manufactured in places like China.

Do you have a solution to fix this?

I think the US should use some monetary means to encourage more companies to produce things in the USA even if that means an increase in costs. However, most obstacles to this are caused by US Regulations and red tape and government red tape. We are shooting ourselves in the foot.
 

Veliko

Diamond Member
Feb 16, 2011
3,597
127
106
This, exactly this. Idiots whine and complain about companies "dodging" taxes or using "loopholes". It's basic logic and we all do it on an individual level as well (as we should), we try to minimize our tax liability within the confines of the law. If you break the law, that's another story, but as long as you stay within the law, I see no problem.

That's because you're a fool.

These same companies who claim to be obeying the law are the ones campaigning for this situation in the first place.
 

dphantom

Diamond Member
Jan 14, 2005
4,763
327
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That's because you're a fool.

These same companies who claim to be obeying the law are the ones campaigning for this situation in the first place.

and you can campaign for your own version of the laws. quit whining and do something about it then
 

Veliko

Diamond Member
Feb 16, 2011
3,597
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and you can campaign for your own version of the laws. quit whining and do something about it then

Another fool.

Do you think these corporations are going to give you a pat on the head if you defend them on the Internet?
 

Sonikku

Lifer
Jun 23, 2005
15,912
4,947
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No. But the point is that these laws are going to be there for us for when we're all big shot billionaires.
 

1prophet

Diamond Member
Aug 17, 2005
5,313
534
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The Chinese have no obamacare and no Social Security, No welfare, No Medicare, and no Welfare.


And they have limited to no equivalent of EPA, OSHA, Labor laws yet the same so called liberal fools here that supposedly support unions, equal pay for equal work, and want higher minimum wages don't think twice when it comes to saving a buck by buying the made in China product over the American one and supporting the free trade agreements that made it so.
 

PokerGuy

Lifer
Jul 2, 2005
13,650
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That's because you're a fool.

These same companies who claim to be obeying the law are the ones campaigning for this situation in the first place.

They don't just claim to be obeying the law, they ARE obeying the law. Just because you don't like the result doesn't mean they're doing anything illegal. So what if they are the ones campaigning for something? How is that relevant?

The law is what it is, and they are following it. If we want them to do something different, we need to change the law, not whine about them following the existing law.
 

Veliko

Diamond Member
Feb 16, 2011
3,597
127
106
They don't just claim to be obeying the law, they ARE obeying the law. Just because you don't like the result doesn't mean they're doing anything illegal. So what if they are the ones campaigning for something? How is that relevant?

The law is what it is, and they are following it. If we want them to do something different, we need to change the law, not whine about them following the existing law.

Your sycophancy will not be rewarded so why bother with it?

Do you think these people will buy you so much as an ice cream for your efforts?