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Wisconsin Union Bill

cjr72 said:
If the income is repatriated back to the US. If not the tax is deferred for as long as they keep the money abroad.
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Source?

The only way that they get out of paying income tax is by having huge US losses, and being able to deduct their foreign taxes from their US tax liability. Those two things can greatly reduce (and eliminate) their US tax debt, but their foreign income is still taxed... it doesn't matter WHERE the money resides.

It's the same for citizens, BTW. You get a nearly $100,000 tax break if you reside outside the US for more than 330 days in 12 consecutive months, but anything beyond that is taxed here... it doesn't matter WHERE you keep your money.
 
Not IRS but here's a couple more references from well known tax policy sites:

TPC Tax Topics | 2010 Budget -* Implement international enforcement, reform deferral, and other tax reform policies:
The president also proposes to change the way the international income of American corporations is taxed. Currently, the U.S. taxes both the domestic and foreign earnings of U.S. corporations. The time at which firms pay U.S. taxes on their foreign profits depends on how the parent company organizes its foreign operations. If operations are organized as subsidiaries (that is, they are separately incorporated in the foreign country), then the profits are generally not taxed until they are paid to the U.S. parent.
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http://www.taxfoundation.org/files/sr174.pdf:
The main tax provision targeted for repeal by critics in the Administration and the Congress
is what
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1)

Subsidiaries are separate companies that are owned by a parent company... the parent company does not pay taxes on income of subsidiaries until that money is transferred to the parent company. That's not just Foreign income, but it's the same for US based subsidiaries as well.

That's because it's not income for the parent company until the parent company receives it.

2)

From your own source

The United States is the only large economy that taxes corporate income worldwide with a tax rate exceeding 30 percent
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During 2009, both Great Britain and Japan enacted territorial systems, giving their multinationals a major tax advantage
over U.S.-based firms that are saddled with a worldwide system. Over 80 percent of developed nations now have
territorial systems
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Whether the U.S. moves to strengthen its worldwide system by repealing deferral or follows the international trend by
adopting a territorial system, there will be unfortunate incentives created. In both cases, though, lowering our corporate
tax rate will mitigate them
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cjr72 said:
Not IRS but here's a couple more references from well known tax policy sites:

TPC Tax Topics | 2010 Budget -* Implement international enforcement, reform deferral, and other tax reform policies:
http://www.taxfoundation.org/files/sr174.pdf:
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Tax Deferral is the process of not sending money back to the parent company immediately from a subsidiary... and works the same way with US based subsidiaries.

Outsourcing Jobs and Taxes - Council on Foreign Relations

Tax Deferral: The United States taxes both domestic and foreign earnings of U.S. multinational firms. Firms time the payment of taxes on their foreign profits based on how their parent company organizes its foreign operations. If a parent company is organized through subsidiaries (separately incorporated in the foreign country), the subsidiaries' profits generally are not taxed until they are paid to the U.S.-based parent.
Parent companies do pay U.S. tax immediately on dividends, interest, or royalties paid by one subsidiary to another. But delayed payments, referred to as "tax deferrals," often do not occur for years. According to a May 2009 Bloomberg article, for example, General Electric has deferred tax on a cumulative $75 billion over the past decade; Hewlett-Packard has deferred $12.9 billion since 2005. Once foreign income is sent back to the United States, the U.S. government imposes a residual tax. Obama's reforms would defer the deductions U.S.-based multinationals take on foreign income until the U.S. tax is paid on that income, effectively raising the cost of delaying those tax payments.
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My point in previous posts is that US multinational corporations take advantage of lower tax rates in foreign countries. The reason they can do that is because the can defer what the difference in rates that they 'owe' to the US indefinitely. Nothing you've posted contradicts that.
 
cjr72 said:
My point in previous posts is that US multinational corporations take advantage of lower tax rates in foreign countries. The reason they can do that is because the can defer what the difference in rates that they 'owe' to the US indefinitely. Nothing you've posted contradicts that.
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Umm... because the company deferring taxes isn't the company that pays taxes in the US.

The company making the foreign profits is NOT the company paying taxes in the US...
 
byteware said:
Umm... because the company deferring taxes isn't the company that pays taxes in the US.

The company making the foreign profits is NOT the company paying taxes in the US...
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Saying a company and it's subsidiaries are not the same company is an overstatement. My previous employer was a multinational corporation with subsidiaries around the world. Our CEO here at home was also theirs. When we would have an all-hands meeting to discuss the new corporate road map (seemed like there was a new road map every 6 months :rolleyes:) it was taped so our offices in other countries could see it. Our team worked with a team in India on the same product. Pretty much the same products localized for different regions were sold around the world. On paper for legal and financial reasons they are defined as subsidiaries but from an operating standpoint they are the same company.
 
cjr72 said:
Saying a company and it's subsidiaries are not the same company is an overstatement.
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Overstatement? It's a legal reality.

cjr72 said:
My previous employer was a multinational corporation with subsidiaries around the world. Our CEO here at home was also theirs.
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A subsidiary is solely owned by another company (otherwise it would be called a joint venture...) So, yes, this would be true.
 
Judge issues temporary hold on Wisconsin 'budget repair' bill

Posted Mar 19, 2011 by ■ Bill Lindner
A Wisconsin Judge issued a temporary hold on Governor Walker's controversial "budget repair" bill, and for the second time in less than a month, reprimanded Wisconsin Republicans for keeping the public out of the legislative process.

■ J Ocean Dennie​


Dane County Judge Maryann Sumi has reportedly issued a temporary restraining order blocking the implementation of Wisconsin Governor Scott Walker's controversial "budget repair" bill on the grounds that the conference committee's passage of the bill likely violated state Open Meetings laws (PDF). Wisconsin Governor Scott Walker has signed the "budget repair" bill that was hurriedly passed by the state legislature, but it won't become law until it's published by Wisconsin Secretary of State Doug LaFollette. By issuing a temporary restraining order, Judge Sumi prevents LaFollette from publishing it until a full hearing takes place. The hearing is currently scheduled for March 29. Judge Sumi, appointed to the bench by a Republican governor in 1998, is the second judge to issue a temporary restraining order against the state of Wisconsin, following Judge John Albert's decision requiring access to the Capitol building earlier this month. Wisconsin Republican Leadership facing more lawsuits Ismael Ozanne, Dane Country District Attorney, filed a lawsuit challenging the March 9 vote by the Wisconsin Senate after it used questionable Parliamentary procedures to alter legislation Walker was trying to push through the legislature with minimal review or public consideration on grounds that it violated Wisconsin Open Meetings laws (PDF). The hurried passage of the controversial legislation was delayed for weeks due to massive protests and the absence of Democrats who deprived the Senate of the quorum necessary for passing budget bills when they left the state. In ruling against the state, Judge Sumi emphasized the importance of open government in a Democracy, reportedly saying "This was something that would and did catch the public unaware in what ended up being a closed session of a body in propelling legislation forward." Wisconsin's Republican leadership is facing other lawsuits as a result of how the "budget repair" bill was passed. Because the Capitol building was in lockdown while the legislature voted on Walker's bill, Judge John Albert is considering whether Department of Administration Secretary Mike Huebsch is in contempt of Albert's Capitol access order. Judge Albert will decide whether or not to make his temporary restraining order permanent in late May. The Wisconsin Employment Relations Commission is also reportedly considering an unfair labor practices complaint from the state employee union AFSCME alleging Governor Walker violated his duty to bargain in good faith.
 
Wait, so the bill isn't being passed because the Democrats, instead of making constructive alterations to bill, went into hiding?
 
Constructive alterations? The union-busting governor's position was that he wanted no alterations. Further, I believe the law requires the governor to negotiate in good faith with the changes he wants. Didn't do that, either.
 
Yeah well the union needs to realize cant get blood from a turnip. If the gov has no money then they have no job and then they have nothing.
 
Dark Jedi said:
Yeah well the union needs to realize cant get blood from a turnip. If the gov has no money then they have no job and then they have nothing.
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Well, that certainly explains why the governor there is giving hundreds of millions in tax cuts to corporations.
 
the law requires good faith when negotiating contracts......... they werent negotiating contracts...... they were creating a new law.... theres a distinct difference...... Im sure under the new law there will still be good faith negotiations for contracts just like there has been in the past

as far as the open meetings complaints...... thats a pretty far stretch........ its not like it was some secret what was in the bill...... that the bill was on the table..... and that the bill would be passed...... its not like they wrote the bill in secret then immediatley pushed it to the floor for an instant vote and passed it before anyone knew what was in it (such as what happened with healthcare on the federal level).... the wisconsin dems were there for every step until they realized they couldnt get their way and fled the state...... once they were back in the state the bill (that everyone already knew what was in it and was up for a vote) was pushed to a quick vote before the dems could flee again

worst case scenario... the judges strike it down on a technicality for open meetings..... then the reps will immediately reintroduce the bill in its exact same current form and put it to a vote again........ leaving the dems with 2 options...... sit and whine some more....... or run away again

to paraphrase Obama: "they won"
 
So, announce the meetings ahead of time, and pass the darned bill right.

It's about time some states reeled in these public unions (FYI... I'm a public employee with a union, that doesn't have collective bargaining rights...)
 
I really shouldn't read these threads. All they do is make me sad at the gullibility of so many Americans. It's a pathetic thing to see so much misinformation and hatred due to lies spread by those who want the lower classes fighting amongst themselves. It really doesn't give me much hope for this country.
 
Tom Ace said:
I really shouldn't read these threads. All they do is make me sad at the gullibility of so many Americans.
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I agree with you here.

It's completely pathetic that people believe what politicians tell them, and see things as a one side is right and good versus the other side is bad and wrong.

Things are never that simple. Both sides are right and both sides are wrong.

But get any more complicated than...."oh, this looks like a good idea", and most Americans brains just shut down.
 
byteware said:
I agree with you here.

It's completely pathetic that people believe what politicians tell them, and see things as a one side is right and good versus the other side is bad and wrong.

Things are never that simple. Both sides are right and both sides are wrong.

But get any more complicated than...."oh, this looks like a good idea", and most Americans brains just shut down.
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Agreed.
 
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