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re: G7 backs Biden's sweeping overhaul of global tax system

Posted on 6/6/21 at 10:37 pm to
Posted by Roaad
White Privilege Broker
Member since Aug 2006
76570 posts
Posted on 6/6/21 at 10:37 pm to
quote:

So you would repeal GILTI? Would you couple that with a rate decrease to keep investment from flowing out?
I am in favor of dramatically lowering corporate tax rates domestically.

quote:

I just want to be clear with what you mean by this--you are OK with countries setting their rates low or do you actually support tax schemes that involve things like treaty abuse?
Part 1: Support

Part 2: Generally anti-treaty
Posted by Roaad
White Privilege Broker
Member since Aug 2006
76570 posts
Posted on 6/6/21 at 10:38 pm to
quote:

This wasn’t actually happening. The Chinese are more than willing to frick over anyone and everyone.

And they have a less regulated financial market than we do.
Posted by sostan
Louisiana
Member since Jul 2010
1065 posts
Posted on 6/6/21 at 11:01 pm to
Of course they do. They are all benefitting from us Americans getting hosed by our president and legislators.
Posted by Jorts R Us
Member since Aug 2013
14860 posts
Posted on 6/7/21 at 4:13 am to
quote:

Part 2: Generally anti-treaty


Then you're generally not "OK with tax havens." I get the sense you'd just as soon not have a corporate income tax or at least keep the rate at a single digit.

I get it. You'd lower rates (vs creating obscenely complicated tax law) to neutralize the effects of base erosion and profit shifting, but we both know how unlikely that is to happen. Given that low probability, is it really preferable to cede tax revenue elsewhere, particularly jurisdictions that encourage little to no substance of operations?
Posted by Roaad
White Privilege Broker
Member since Aug 2006
76570 posts
Posted on 6/7/21 at 9:13 am to
quote:

quote:

Part 2: Generally anti-treaty



Then you're generally not "OK with tax havens."
You are confused.

I am saying I am OK with a government with lower tax rates being used by business as a tax haven. That can be done without a single treaty, assuming nations have the right to set their own tax rates.
Posted by boogiewoogie1978
Little Rock
Member since Aug 2012
17066 posts
Posted on 6/7/21 at 9:34 am to
quote:

Non G7 countries finna FEAST!

No they're not. Most are unstable and can't be relied upon for business.
Posted by Jorts R Us
Member since Aug 2013
14860 posts
Posted on 6/7/21 at 9:44 am to
quote:

You are confused.

I am saying I am OK with a government with lower tax rates being used by business as a tax haven. That can be done without a single treaty, assuming nations have the right to set their own tax rates.



I'm not confused at all. I think I clearly acknowledged that what you are OK with is low tax rates.

But you can't simultaneously be anti-treaty and ok with tax havens considering that treaties is one of the tools that tax havens use to shelter income from taxation in any jurisdiction.

Ireland and Hungary both have low CIT rates. Only one of those is regularly labeled a tax haven. Ireland's 12.5% rate isn't what gets them that label. It's the fun and games they play with treaties with jurisdictions like Malta to give a bunch of profits no tax home. Someone that is anti-treaty shouldn't be OK with the Irish Single Malt structure.

So I think what you mean to say is you are OK with countries setting their rates low. That in itself would be a feat, but unless you go to nil, you're still going to have to contend with countries like Ireland that like to ride the line which means you're going to need anti-BEPS provisions in your tax code.

In short, what you champion is improbable and impractical.
This post was edited on 6/7/21 at 9:54 am
Posted by ibldprplgld
Member since Feb 2008
25082 posts
Posted on 6/7/21 at 9:57 am to
Lol China finna eat while these 7 countries stupidly hamstring their own economies.

Can’t wait to hear about how all these jobs being offshored from US soil is a good thing. Progs? Any takers?
Posted by Jorts R Us
Member since Aug 2013
14860 posts
Posted on 6/7/21 at 10:06 am to
quote:

No they're not. Most are unstable and can't be relied upon for business.


I often see China and Russia referenced as two jurisdictions that won't comply. My response to that is "And?" Neither have particularly attractive CIT rates and for obvious reasons they aren't attractive places to park your IP or lending subsidiaries.

Now, countries like Ireland eat but here is no "Finna" about it. Ireland already eats, and it isn't the rate. It's taking advantage of hybrid entities or their treaty network. Then when the EU makes them cave and give up those plays they come up with intangible property plays. Even if Ireland agreed to go to 15%, it wouldn't matter.
This post was edited on 6/7/21 at 10:10 am
Posted by Jorts R Us
Member since Aug 2013
14860 posts
Posted on 6/7/21 at 10:09 am to
quote:

Lol China finna eat while these 7 countries stupidly hamstring their own economies. Can’t wait to hear about how all these jobs being offshored from US soil is a good thing. Progs? Any takers?


Well, yeah, a global minimum tax rate isn't going to cancel out cheap labor but China won't be the primary beneficiary of this. No one wants to park FINCO's and IP in China. Hell, people are keeping an eye on Hong Kong so they can get their FINCO's the frick out.
This post was edited on 6/7/21 at 10:11 am
Posted by lsu777
Lake Charles
Member since Jan 2004
31443 posts
Posted on 6/7/21 at 10:10 am to
frick all those marxist fricks. bunch of geriatric cock suckers trying to hold on to the past. frick em.
Posted by WeeWee
Member since Aug 2012
40191 posts
Posted on 6/7/21 at 11:06 am to
quote:

Uh huh. And why aren't they currently "eating" considering our rate is 21%?



Ireland is already eating. Ireland is a tax haven that accounts for 3.7% of lost global corporate income taxes. Being based in Ireland allowed Apple to avoid paying the 13,000,000,000 EUR in corporate taxes to the EU recently.

Hungary is becoming a tax haven, but it still lacks the high skilled labor pool to be attractive to countries. Plus like other central and eastern european countries it is still dealing with a corruption problem.
Posted by wutangfinancial
Treasure Valley
Member since Sep 2015
11196 posts
Posted on 6/7/21 at 11:11 am to
I want the Feds to go scorched earth on these over leveraged POS companies that have been bowing to the CCP. Frick them in the arse with taxes and anti-trust
Posted by Jorts R Us
Member since Aug 2013
14860 posts
Posted on 6/7/21 at 11:13 am to
quote:

Ireland is already eating


That's exactly my point, so what is this "finna" nonsense?
Posted by WeeWee
Member since Aug 2012
40191 posts
Posted on 6/7/21 at 11:24 am to
quote:

Ireland is already eating


That's exactly my point, so what is this "finna" nonsense?


Finna eat more. There are you happy?
Posted by Vacherie Saint
Member since Aug 2015
39575 posts
Posted on 6/7/21 at 11:27 am to
no one is "finna" do anything.

this is a handful of finance ministers saying that they agree on policy. They have zero power to enact this in their own nations much less globally. its meaningless talk.
Posted by Jorts R Us
Member since Aug 2013
14860 posts
Posted on 6/7/21 at 11:29 am to
quote:

Finna eat more. There are you happy?


It will be irrelevant because they eat because of their CAIA regime, not because they refuse to raise their rate 2.5%. No substance to the "Finna" comment but don't let that stop you from hyping this up.

Hell, we cut the corporate rate dramatically and Ireland still found a way to turn our minimum tax on foreign earnings into a net positive for them.
This post was edited on 6/7/21 at 11:42 am
Posted by Aubie Spr96
lolwut?
Member since Dec 2009
41201 posts
Posted on 6/7/21 at 11:30 am to
quote:

Group of Seven finance ministers gathering in London agreed Saturday to back a global minimum tax of at least 15% on multinational companies. The G7 group also agreed that the biggest companies should pay tax where they generate sales, and not just where they have a physical presence.



frick THESE PEOPLE.
Posted by mmcgrath
Indianapolis
Member since Feb 2010
35474 posts
Posted on 6/7/21 at 11:50 am to
quote:

G7 backs Biden's sweeping overhaul of global tax system
Wouldn't even be possible without Republicans putting us in a territorial tax system like the rest of the world. But "leveling the playing field" was the carrion call.
Posted by Jorts R Us
Member since Aug 2013
14860 posts
Posted on 6/7/21 at 12:50 pm to
quote:

Wouldn't even be possible without Republicans putting us in a territorial tax system like the rest of the world. But "leveling the playing field" was the carrion call.


We don't have territorial. We have a participation exemption regime. And we needed to get off worldwide.
This post was edited on 6/7/21 at 12:52 pm
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