17/1/18: Apple's Plans for Foreign Cash and the Need for Larger Reforms

There is a lot that can be criticized in the GOP/Trump tax reforms passed late last year, but some things do make sense. Back in November 2016, in my column for the Cayman Financial Review (see here: http://trueeconomics.blogspot.com/2016/11/31116-cfr-tax-cure-for-american.html), I argued that a comprehensive tax reform of the U.S. corporate tax system, alongside a generous repatriation scheme for off-shored profits of the U.S. MNCs can provide a significant boost to the U.S. economy.

Today, we got some news confirming my assertion. Apple is planning to bring some USD350 billion back to the U.S. with a large scale investment portfolio aligned to this repatriation: https://www.cnbc.com/2018/01/17/apple-announces-350-billion-investment-20k-jobs-over-5-years.html.

However, to really lock in the new investment, President Trump and the Congress need to significantly revamp the existent system of work permits, work and business visas, starting with the current H1B system. Returning financial capital back to the U.S. is but the first step on the road to increasing the U.S. economic potential.

The second step must be opening up U.S. labor and entrepreneurship markets to inflow of talent from abroad (these markets are currently extremely closed). This will require not only revising numerical quotas, but also the following:

1. Shifting admissions away from contingent workforce employers (contractors) and in favor of direct employment and sustainable, skills-based self-employment;
2. Increasing ability (and incentives) for integration into the American society for newcomers (including, but not limited to, improving bureaucratic barriers to access to permanent residency and naturalization, improving the culture and the climate of government bureaucracies vis-a-vis higher skilled newcomers, etc);
3. Creating new, more open, programs for entry into the U.S. for highly skilled and entrepreneurial migrants; and
4. Encouraging greater mobility across employers for foreign highly skilled workers.

The third step must involve regulatory reforms that remove markets, financial & contractual supports for incumbent monopolistic firms (the rent-seekers, like big telecoms, large banks, automakers, etc). Opening the sectors to genuine competition will be the only chance the U.S. has to compete with the likes of China, and increase its own potential GDP).

Finally, the fourth step (partially already targeted by the recent tax reforms) must involve reducing the burden of direct and indirect taxes on the American wage earners, especially those with higher skills levels. The key here is to focus on both, direct and indirect taxation, and the latter, in my opinion, includes the cost of healthcare and pensions. 

Apple's announcement is the good news. And President Trump does deserve credit on this.  But tax holiday alone won't fix the problem of economic sclerosis that has plagued the U.S. economy for a good part of two decades now.

7/12/16: Bloomberg Blows the Cover on Apple's Irish Tax Dodge, Again

So you know the $13 billion that Apple, allegedly, owes Ireland?.. It really never did owe Ireland much. Instead, it owes the money to taxpayers outside Ireland - in countries where actual business activities took place and in the U.S., where Apple tax avoidance scheme starts, ends and start again. Here's how Bloomberg explains it: https://www.bloomberg.com/graphics/2016-apple-profits/

Oh, yeah, you are reading it right: "a popular corporate tax haven"... that'll be Ireland (per Bloomberg). expect loud protests from Dublin to Bloomberg offices and, potentially, a re-drawing of the scheme to alter the wording...

But you do get an idea: 10 years, at, say $600 million payments, that'll be almost half the $13 billion 'owed to Ireland' that is really U.S. taxpayers cash...

21/9/16: Apple Tax Case: Not the Rate, the Loopholes

My column for the Village covering the Apple Tax fiasco: http://villagemagazine.ie/index.php/2016/09/not-the-rate-the-loopholes/

As it says on the 'tin' - the problem with Apple Tax is not the rate of corporate taxation set in law in Ireland (the 12.5% 'red line' rate), and not tax competition, nor the benign nature of tax exemptions that Ireland bestows on all companies, including the MNCs. The problem is that these competitive aspects of the Irish regime are simply not enough for the likes of Apple, which pursued and obtained access to exemptions that any ordinary company operating in Ireland cannot avail of.

Hence, the red herring of the arguments that the EU Competition ruling is an attack on Irish tax rate. It is, instead, a challenge to the asymmetric preferences granted in the past (and still in use during the ongoing phase-out period) to a handful of MNCs over and above domestic companies. Lest we forget, for decades, Irish State had no qualms operating an openly discriminatory taxation regime that treated foreign investment-backed companies differently from domestic companies. Lest we omit considering the present, Irish State still has no qualms taxing human capital of its residents at rates far in excess of those applying to physical and financial capital. Lest we fail to think about it, Irish State has no qualms asymmetrically allocating the burden of the crisis to Irish people over and above our banks, foreign investors, foreign bondholders and vulture funds.

I am one of the most vocal advocates of low (benign) taxation, flat tax, competitive regulatory regimes (coupled with robust enforcement) and other means for improving the functioning of the private markets. Always been one and remain. I support real investment in the economy, both foreign and domestic and believe in a level playing field for entrepreneurs and enterprises, alike. But, folks, the debate around Apple Tax is not about 12.5% tax rate and Ireland's tax autonomy, but about asymmetric nature of privilege.

14/9/16: Apple Tax on Keiser Report

My interview with Max Keiser for Keiser Report on Apple Tax fiasco: https://www.rt.com/shows/keiser-report/358886-episode-max-keiser-965/

29/7/16: Tax Regime, Apple, Fraud?

We have finally arrived: a Nobel Prize winner, former Chief Economist and Senior Vice-President of the World Bank (1997-2000) on Bloomberg, calling Apple's use of the Irish Tax Regime 'a fraud': http://www.bloomberg.com/news/articles/2016-07-28/stiglitz-calls-apple-s-profit-reporting-in-ireland-a-fraud?utm_content=business&utm_campaign=socialflow-organic&utm_source=twitter&utm_medium=social&cmpid%253D=socialflow-twitter-business.

This gotta be doing marvels to our reputation as a place for doing business and for trading into Europe and the U.S.

The same as Facebook's newest troubles: http://www.irishtimes.com/business/technology/facebook-tax-bill-over-ireland-operation-could-cost-5-billion-1.2738677.

But do remember, officially, Ireland is not a tax haven, nor is there, officially, anything questionable going on anywhere here. Just 26.3 percent growth in GDP per annum, and booming corporate tax revenues that the Minister for Finance can't explain.

13/4/15: That Utilitarian Logic of EU Tax Probes...

Yet another international publication, this time The Economist, is going off the Irish Government 'reservation' with an article on how Apple is being 'helped' to tax avoidance: http://www.economist.com/news/business/21621810-multinationals-deals-tax-friendly-countries-are-coming-under-fire-bit-too-cosy?fsrc=scn/tw_ec/a_bit_too_cosy_. The farce is, it is the very same State that enabled this practice which now stands to gain from the unwinding of the practice.

Ah, the logic of the European Union... it is, rather, err... relativist in nature...

9/9/2014: iPhone 6 Dilemma for Ireland?..

And so it comes... the iPhone 6 is about to be launched, and Apple has a major dilemma. Hype in the market suggests bumper sales for the new phone. But sales mean profits. And profits, for Apple, mean growing a pile of cash stashed in off-shore locations, including Ireland that the company can't do much with. Get the dilemma? The Guardian did: http://www.theguardian.com/technology/2014/sep/07/apple-iphone-6-cash-pile-tax-avoidance-us?curator=MediaREDEF.

I covered this earlier: http://trueeconomics.blogspot.ie/2014/06/2562014-imf-on-corporate-tax-spillovers.html as well as within the context of the overall position of Ireland as a corporate tax non-haven (you can track the topic from the links starting here: http://trueeconomics.blogspot.ie/2014/08/2682014-betting-on-corporate-tax.html).

Lest we forget: in the last 12 months through Q1 2014 (the latest for which data is available), Irish economy shipped out EUR26.678 billion in net factor payments abroad (these are, roughly, profits paid out to foreign entities out of Ireland, net of profits from Irish investments abroad). In the same 12 months period of 2012-2013, the amount was EUR28.517. Which means that in the 12 months through Q1 2014, cash repatriation out of Ireland was EUR1.839 billion lower than a year before. This contributed positively to our GDP. But our GDP over the same period rose by EUR1.953 billion. So if profits repatriation was running in 12 months through Q1 2014 at the same rate as in 12 months through Q1 2013, our GDP would have risen not by EUR1.953 billion (+1.13%) but by EUR114 million (+0.07%).

Let's take a look at Apple, again: the company has USD140 billion worth of cash stashed around the world, with much of this - by various reports between USD60 and USD90 billion via Ireland. Take a lower envelope and start repatriating... there can be a risk of a serious recession in Ireland were this to happen.

Ah, all the worries of the FDI-rich Ireland, the best little country to do tax business from...

20/6/2014: Some recent media links for TrueEconomics

Few recent media links citing TrueEconomics or/and myself:

1. Finfacts on Mortgages Arrears in Ireland: http://www.finfacts.ie/irishfinancenews/article_1027769.shtml Delighted to see my analysis cited by Finfacts.
2. CityAM citing TrueEconomics post on duration of US unemployment: http://www.cityam.com/blog/1402402353/uks-scariest-chart-dead-gdp-finally-passes-pre-crisis-peak
3. TechInsider citing from my CNBC interview on EU Commission investigation of Apple Inc tax practices in Ireland: http://www.techinsider.net/apple-inc-aapl-starbucks-corporation-sbux-taking-advantage-of-tax-benefits-in-europe/115804.html video of my interview is also linked at the bottom of the post.
4. The Washington Times cites from TrueEconomics post on Russia-China gas deal: http://www.washingtontimes.com/news/2014/may/25/russias-putin-gains-strategic-victory-with-chinese/?page=all the original post referenced is here: http://trueeconomics.blogspot.ie/2014/05/2152014-russia-china-gas-deal.html

No links to mainstream Irish media.

17/6/2014: Ireland's Regulatory 'Resource Curse'

My WallStreet Journal op-ed on the European Commission's investigation into Apple tax affairs in Ireland is linked here.

19/10/2013: WLASze Part 2: Weekend Links on Arts, Sciences and zero economics

This is the second post of my WLASze: Weekend Links on Arts, Sciences, and zero economics for this week.

Enjoy and be warned, I do stray into 'some' economics (but only as 'science') in this one...


"By discovering a new set of solutions to the famous Maxwell equations governing electromagnetism, Hridesh Kedia of the University of Chicago and his colleagues have shown that light can be tied up in knots. Here the purple and gold cords represent the twisted magnetic field lines of knotted light." Ughh?.. No, really cool - read more here: http://www.scientificamerican.com/article.cfm?id=tying-light-in-knots-slide-show

And… "The same University of Chicago lab, led by William Irvine, also recently discovered a way to tie water up in knots. This photograph shows a basic knotted shape called a trefoil knot made of water, imaged by light scattering off tiny gas bubbles in the liquid."

Question for scientists… can anyone untie the knots of Irish policymakers' ideas? Like the following conjecture: to deal with the effects of the property bubble collapse, Budgets 2010-2014 introduced series of property markets tax incentives… Bet that'll be harder than Maxwell's equations…


But this is WLASze, so let us not dwell too long on matters of Irish policies. Even if for the purpose of advancing the science of the bizarre…

So back to sciences: "Society's techno-social systems are becoming ever faster and more computer-orientated. However, far from simply generating faster versions of existing behaviour, we show that this speed-up can generate a new behavioural regime as humans lose the ability to intervene in real time."

Ok, this is potent stuff. And where better to look for such 'machine outpaces mankind to defeat the entire purpose of the human-made system' than in financial markets (I can't shake off this year's 'Nobel' in Economics)… So: "Analyzing millisecond-scale data for the world's largest and most powerful techno-social system, the global financial market, we uncover an abrupt transition to a new all-machine phase characterized by large numbers of subsecond extreme events. The proliferation of these subsecond events shows an intriguing correlation with the onset of the system-wide financial collapse in 2008. Our findings are consistent with an emerging ecology of competitive machines featuring ‘crowds’ of predatory algorithms, and highlight the need for a new scientific theory of subsecond financial phenomena."

Here's the full article: http://www.nature.com/srep/2013/130911/srep02627/pdf/srep02627.pdf

Wanna see something really scary?

Or in different visualisation:

Ok, now that I am onto Financial Markets and their 'efficiency' - a compendium of links explaining this year's Nobel Memorial Prize in Economics. No commented from me:

• http://asociologist.com/2013/10/14/you-cant-beat-the-market-but-the-market-can-beat-you/
• http://delong.typepad.com/sdj/2013/10/a-note-on-the-2013-nobel-like-prize-in-economics.html
• http://afinetheorem.wordpress.com/2013/10/14/a-brief-word-on-the-2013-nobel/
• http://noahpinionblog.blogspot.ie/2013/10/lars-peter-hansen-explained-kind-of.html
• http://krugman.blogs.nytimes.com/2013/10/14/the-nobel/?_r=1
• http://johnhcochrane.blogspot.kr/2013/10/gene-famas-nobel.html
• http://blogs.ft.com/ft-long-short/2013/10/14/fama-shiller/
• http://simplystatistics.org/2013/10/14/why-did-lars-peter-hansen-win-the-nobel-prize-generalized-method-of-moments-explained/

Now I've done it… this was supposed to be WLASze and it is now more Finance & Economics than Arts or Sciences…

I recently wrote about the determinants of what makes content go viral on social networks (see link here). The study was based on Google+ - a network that Google seems to think is a major one, yet everyone else seems to think of as a 'may be one day' contender. Now, more real viral propagation visualisation via twitter:

Link: http://blogs.hbr.org/2013/08/visualizing-how-online-word-of/


As Apple is pushing ahead with the meat (USD5 billion) plan for new HQs in Cupertino, CA, here's an overview of the project: http://www.dezeen.com/2013/10/16/fosters-apple-campus-unanimously-approved-by-cupertino-city-council/

Yes, buildings of this scale are a challenge. Yes, aesthetics of the corporate identity at this scale are a challenge. Yes, Apple is strongly 'impositional' organisation with emotional attachment to 'eco-sthetics' and reality of a massive Death Star orb floating in alien space… so then, yes, the plans are perfectly befitting the client…

As a life-long fan of Apple (I still have a working-order first marketed laptop by the company in my collection and our household has a pile of interconnected Apple devices) all I can say is, sadly, with the shift in Apple's fortunes, the company is now running out of ideas… But wait, I am not alone: http://www.dezeen.com/2013/09/13/apple-has-reached-creative-saturation-says-steve-jobs-colleague-hartmut-esslinger/


On a beautiful side (to round off this week's WLASze): Gagosian Gallery is hosting a Willem De Kooning Ten paintings show, comes November 8:
http://www.gagosian.com/exhibitions/willem-de-kooning--november-08-2013

De Kooning is a master of light and contrast, depth and balancing extremal abstract expressionism with minimalism. His work is stark, striking, bright with simplified, distilled essence of countering colour and movement and space. These are his later works, right before his death in 1997.

The middle image above is taken from the coverage of the MoMA retrospective of de Kooning's works back in 2011.

It was not always thus, as you can see from his earlier works, such as Gotham News, 1955:

You can see more of de Kooning's works here: http://www.benditz.de/ and here: http://theartstack.com/artists/willem-de-kooning

Enjoy. De Kooning is a great master with deep, often disturbed depth of psychological insight alternating with organic capacity to surprise, to open up that momentary window into viewer's own imagination...

7/6/2013: Weekend Reading Links: Part 2

In the previous post I have compiled some reading links for the weekend: http://trueeconomics.blogspot.ie/2013/06/762013-weekend-reading-links-part-1.html

As promised, here is a follow up second post with the rest of links.


The world of clocks and daggers is, it turns out, also the world of some appreciation for the arts. As reported here: http://www.wired.com/threatlevel/2013/06/analyst-who-cracked-kryptos/ the CIA staff has finally cracked the code of the Jim Sanborn's cryptographic sculpture at the CIA’s HQs. It took 8 years and then it took another 25 years for the fact to be revealed to the public. But even more fascinatingly, one last coded section of the sculpture is yet to be deciphered…


Not exactly art or science, but Apple is a leading light in the world of design-driven approach to manufacturing. It has been brilliant, irreverent, non-standard and always expressive through out decades. It has also been a brand icon for creative industries )rows of Macs on ad agencies desks) and as such it is associated with the very iconic anti-IBM commercial that launched it http://www.youtube.com/watch?v=VjyrqVgWPXY.

But now, Apple is the new IBM… http://blog.stephengates.com/2010/04/12/welcome-to-1984-how-apple-has-become-the-new-ibm/ and worse, it is anti-Apple too, for the man who did this: http://www.youtube.com/watch?v=FXGrVEnKDko would have probably never been hired into Apple today: http://venturebeat.com/2013/06/03/if-steve-jobs-applied-for-a-job-at-apple-today-theres-no-chance-in-hell-hed-get-hired/ .


The next link, as I promised not to do anything 'economics'-wise, is not so much about economics of something, but rather economics as a field of inquiry. Anyhow, I find it intelligently written and actually quite good: http://www.theatlantic.com/business/archive/2013/06/should-we-trust-economists/276497/


Two related articles on art of light:
http://www.theartnewspaper.com/articles/What-happens-when-the-lights-go-out/29752
and
http://www.theartnewspaper.com/articles/Flavins-will-see-the-light-of-day/29751

I prefer Dan Flavin's works: here he is in his symmetric error of homage to Tatlin: http://www.moma.org/collection/object.php?object_id=81337

Of course, irony has it, Tatlin was asymmetric: http://kdigital.tumblr.com/post/576318843/model-for-the-monument-to-the-third-international It always puzzled me why in all of his homages to Tatlin (of which Flavin made 8) he was always symmetric in interpreting Tatlin's tower. All said, here's Flavin at his best http://www.davidzwirner.com/wp-content/uploads/2011/11/33-400x266.jpg

And finally - another reminder - I will be taking part in http://www.rar.ie/ on Thursday 13 June, 2013, from 8.00pm – 2.30am.


Have a great weekend and stay tuned - there will be economics posts on the blog.

26/5/2013: Corporate Tax Haven Ireland Weekly Links Page

"Taxes are not up to Google," Schmidt reiterated. "If the international tax regime changes we will follow. But virtually all American companies have structures like this; this is how the international tax regime works. The fact of the matter is if we pay more tax in one area, we pay less somewhere else."

Thus spoke Eric Schmidt of Google (http://www.wired.co.uk/news/archive/2013-05/22/eric-schmidt-tax) and guess what: he is right. Google is not breaking the law. It is the law that allows for countries, like Ireland, to follow beggar thy neighbour economic policies and strategies.

The issue is not the low tax rate, but the fact that various loopholes allow companies operating - allegedly in Ireland - to channel revenues from other countries into Ireland. This is not about exports from Ireland, and it is not about low tax regime in Ireland. When an MNC books revenue earned somewhere else to Dublin, MNC is not break a law. Instead, Ireland is facilitating transfer of funds that relate to value added activity elsewhere to its own economy. This, in the nutshell, summarises the entire nature of Irish economic development strategy: take value added from somewhere else and appropriate it as Irish.


And in the spirit of usual weekly posts (see thread start on Irish Corporate Tax Haven here: http://trueeconomics.blogspot.ie/2013/05/1452013-corporate-tax-haven-ireland.html ): in this week, it is virtually impossible to list all Tax Haven Ireland links from around the world in a post, but here are some:

• http://www.irishexaminer.com/business/eu-eyes-tax-residency-law-change-232325.html
• several listed here: http://trueeconomics.blogspot.ie/2013/05/26052013-ireland-hard-at-work-on-troika.html
• An important link from March 2013: http://www.finfacts.ie/irishfinancenews/article_1025752.shtml
• Noonan's feeble defence of the regime he claims doesn't exist: http://www.irishtimes.com/news/politics/oireachtas/us-senate-committee-quoted-incorrect-tax-rates-for-apple-activities-here-d%C3%A1il-told-1.1404834
• And here is an 'official' admission that we might change that which, allegedly, does not need to be changed because it is not an 'Irish' problem: http://www.reuters.com/article/2013/05/26/us-ireland-tax-reform-idUSBRE94P04820130526?feedType=RSS&feedName=businessNews
• Of course, the problem does not exist: http://www.rte.ie/news/2013/0522/451805-tax-ireland-apple/
• But things are smelling of some smoke: http://www.euronews.com/2013/05/22/ireland-branded-tax-haven-ahead-of-eu-summit-on-tax-evasion/
• and the smoke ain't white: http://venturebeat.com/2013/05/22/ireland-were-no-tax-haven-but-yes-apple-did-pay-2-tax/
• Vincent Browne wades in with some good links: http://www.irishtimes.com/business/economy/government-zealously-protects-the-wealthy-in-ireland-s-wild-west-tax-haven-1.1401752
• Recall Budget 2013 'Strategy' on Corporate Tax (betcha you didn't know we had this strand of thinking flowing through...) http://budget.gov.ie/budgets/2013/Documents/Budget%202013%20-%20Presentation%20on%20Corporation%20Tax%20and%20FDI.pdf
• IDA Tax 'Guide" from 2012: http://www.idaireland.com/news-media/publications/library-publications/ida-ireland-publications/IDA_Tax_2012.pdf you have to love Figure 3:

• Accountants' view: http://www.annebrady.ie/page6/page35/page91/page91.html Note that 'statutory transparency and uniformity' principle really is not what is being used as core discriptor of Irish regime...
• An interesting 2012 document from IAM on the value of tax regime to Ireland's capacity to attract FDI - as in tax being a singularly most important factor http://www.iamireland.ie/dashboard//upload/134522238057FDI_and_Tax_16th_August_2012.doc
• Jim Stewart's paper on Irish Corporation Tax regime: http://www.tcd.ie/iiis/documents/discussion/pdfs/iiisdp375.pdf This concluded that "The corporate tax rate in Ireland is often described at the ‘cornerstone’ of industrial policy. This paper argues that excessive reliance on tax reliefs and on the attraction/retention of foreign direct investment has led to the development of certain tax haven type features for the Irish economy. Tax haven type features are in turn at variance with the development of sustainable firms."
• CS Monitor article on Google and Apple cases: http://www.csmonitor.com/World/Europe/2013/0521/Google-Apple-draw-transatlantic-ire-over-double-Irish-tax-haven
• Counterbalance from one of the few knowledgeable people on the subject: http://www.independent.ie/business/irish/peter-vale-five-reasons-why-ireland-is-not-a-tax-haven-29287879.html

I shall stop there, for now...

25/5/2013: Saturday Reading Links

Some interesting reading links:

FT Weekend edition has a full supplement on Venice Biennale 2013 - no link, but here's the official page: http://www.labiennale.org/en/art/exhibition/index.html?back=true


A fascinating article from The Economist on the movement toward technology displacing 'knowledge' workers next: http://www.economist.com/news/business/21578360-brain-work-may-be-going-way-manual-work-age-smart-machines

This cuts across my own view that we are seeing rising complementarity between technology and human capital, as opposed to substitutability thesis advanced in the article. The Economist view is thought provoking, for sure.


At last, there is a proof of the theorem that postulates that gaps between prime numbers are bounded: http://blogs.ethz.ch/kowalski/2013/05/21/bounded-gaps-between-primes/ and more on same http://www.slate.com/articles/health_and_science/do_the_math/2013/05/yitang_zhang_twin_primes_conjecture_a_huge_discovery_about_prime_numbers.single.html


An excellent piece on the changes big data is bringing to economics - not from the point of view of new studies directions, but from the point of view of verifiability: http://www.guardian.co.uk/business/economics-blog/2013/may/17/economic-big-data-rogoff-reinhart?CMP=twt_gu
There added 'bonus' points in the article discussing overall relationship between the research recognition, rewards and background work.


And a brilliant example of just how atavistic and primitive is the understanding of the web-based and mobile-platformed services in the top political echelons in Europe:
http://www.telegraph.co.uk/finance/newsbysector/mediatechnologyandtelecoms/electronics/10054717/France-preparing-tax-on-Apple-and-Google-to-fund-culture.html
Apparently, dinosaurs in French political elites have trouble comprehending just how revolutionary to culture and its creators (artists, thinkers, analysts, developers etc) Apple 'i'- and Google platforms are. It is highly likely that iTunes, for example, are doing more to distribution of Francophone music across the world than the entire Ministry of 'French' Culture. Then again, the entire tax debate in Europe is never about culture or arts or anything tangible, but about finding ever more elaborate and bizarre paths for milking the economy to sustain ever expanding state.


While on topic of matters European, a fascinating study on genetic persistency in European populations covered in http://www.presseurop.eu/en/content/article/3770411-europeans-we-re-all-kissing-cousins
Given it comes from the US (original home to Apple and Google), may be the French can pay a special levy to the US for bothering to include their subjects in global research? Afterall, shall they fail to pay up, ignoring France should not be that hard - it works in geopolitics and economics, after all...