Wednesday, July 27, 2022

An Age Old Multinational Taxation Question: Where, Exactly, Does US Tax "Equity" Come To Rest? Which Nation's Jobs Should Be... On The Block, For Chopping?


We have covered, for over a decade, the delicate balance between creating high-paying jobs in Northern Ireland (and elsewhere in the EU), and still fairly paying the IRS, for profits on wonder-drugs like Keytruda® (since the highest-priced sales mostly occur in the US).

But the way international taxation laws work (or, actually don't really work). . . Merck and all big multinational public companies see a vast incentive for moving profits offshore. Apple plainly included, here. The way they do it is to set up Irish financial consolidation centers, where the revenue and profits are actually booked -- and use many many high paid, skilled English speaking cousins o' mine, as employees.

Then, via a series of complicated EU denominated debt offerings, into the multiple billions of euros, these companies (Merck and Apple; Pfizer and Amazon too) set up liabilities that must be paid down, in the US. So, the companies eventually bring back EU cash to pay the EU denominated debt. . . and are able to move all those off-shored earnings back, very efficiently from a US tax standpoint.

I am not defending any of it, as any form of wise policy, but I will say that the Senate Finance Committee's renewed focus on it (last closely examined while Mr. Obama was in office). . . might lead to some real reforms -- and hopefully, strike a balance between paying ones' fair share -- and not cratering the Irish economy, as just one example.

As it is, while the US and EU workers enjoy the highest prevailing wage rates at all these companies. . . the rise of unions anew may well mean that "US tax paying equity" is back on the table. We shall see.

Excuse any typos, this was typed on an iPhone (tiny keys; big fingers) in the car bumping along at 55 mph-plus. . . yep, from the road. Off to the botanic gardens, in a change of venues. . . smile. Cliffs tomorrow -- or Friday.

नमस्ते

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