ucim wrote:No, not really. The purpose of taxation is to enable government to provide indirect benefits. The entity being taxed should be the one deciding that they should be taxed, and they would do so in order to achieve those indirect benefits. That's the whole "taxation with[out] represntation thing. A big multinational gets benefits from (and due to) participating in many geopolitical areas far beyond its corporate home, and therefore it is reasonable that it be taxed in/by those areas, without regard to its corporate home. An analogous situation with people is that while most of a person's government benefit accrues from their home location, people are taxed in/from other areas too, and for essentially the same reasons.
You've wandered afar. For purposes of business they have to be somewhere. In Apple's case they are incorporated in Delaware among other places. Read this article
from Australia. For more amusement read this
A key quote from the report explains why AOI exists:
Apple explained that, although AOI has been incorporated in Ireland since 1980, it has not declared a tax residency in Ireland or any other country and so has not paid any corporate income tax to any national government in the past 5 years. Apple has exploited a difference between Irish and U.S. tax residency rules. Ireland uses a management and control test to determine tax residency, while the United States determines tax residency based upon the entity’s place of formation. Apple explained that, although AOI is incorporated in Ireland, it is not tax resident in Ireland, because AOI is neither managed nor controlled in Ireland. Apple also maintained that, because AOI was not incorporated in the United States, AOI is not a U.S. tax resident under U.S. tax law either.
ucim wrote:It's not orthogonal; tax liability depends very strongly on exactly what one is doing, how one is doing it, where one is doing it... which for a multinational is complex. Which is my point.
For the purpose of the US Treasury, Apple's profits are taxable if they come home which is why they aren't brought here. I don't care how they got them and neither does Treasury. That's what being incorporated in business means. All the business they do is complex. Their profit isn't, and it is what is being taxed.
ucim wrote:Uh... no. Sure, summaries and sound bytes are given to investors, but not to the same degree that the tax agencies require for their own purposes.
I would expect civil liability to occur if the profit Apple states to their investors is less than what they state to the government and would expect criminal liability where Apple states more profit to investors than it states to the government.. What is exactly does profit mean to you?
ucim wrote:I already told you. It represents an aggregate opinion of potential buyers and sellers about the future of the company as balanced against the future of other companies, currency itself, and the geopolitical climate. You are proposing taxing entities based on the opinions of third parties of what the future holds.
It represents ownership. How its valued represents peoples opinion. If I own 100 percent of the stock Tim Cook dances to my tune.
ucim wrote:I suppose one way to implement your plan would be that the government simply confiscates some percentage of a company's stock every year. I don't really see that ending well either though, and a company based in Cupertino whose major operations are actually in Ireland would be gradually eaten by.... who? And what if their (non-revenue-producing) research department operates in France?
Or you could just slap a tax on a percentage of that. Or you could do what we are doing now, nothing.
Tyndmyr wrote:This could be abused hilariously.
Well sure it could, just like the present system. As a point of opinion I don't think it would work either, neither do I think would any of the other ideas. Whatever you think of can be twisted by someone who can think as well or better than you.