Lets talk about tax loop holes.

Diabolical_Dos

Diabolical_Dos

Unverified Legion of Trill member
I do not advocte to use these are find a way out of paying taxes.

im just killing time during the quarantine.

Im going to post up a few of them....some with videos.

Lets start with,......


Double irish with a dutch sandwich.
sound like something from oceans eleven?
Its a real thing....Used by Google , Amazon, Facebook and a few other companies to save on taxes.

What Is the Double Irish With a Dutch Sandwich?
The double Irish with a Dutch sandwich is a tax avoidance technique employed by certain large corporations, involving the use of a combination of Irish and Dutch subsidiary companies to shift profits to low or no-tax jurisdictions. The technique has made it possible for certain corporations to reduce their overall corporate tax rates dramatically.


Understanding Double Irish With a Dutch Sandwich
The double Irish with a Dutch sandwich is just one of a class of similar international tax avoidance schemes. Each involves arranging transactions between subsidiary companies to take advantage of the idiosyncrasies of various national tax codes.

These techniques are most prominently used by tech companies because these firms can easily shift large portions of profits to other countries by assigning intellectual property rights to subsidiaries abroad.

The double Irish with a Dutch sandwich is generally considered to be an aggressive tax planning strategy used by some of the world's largest corporations. In 2014, it came under heavy scrutiny, especially from the U.S. and the European Union, when it was discovered that this technique facilitated the transfer of several billion dollars annually tax-free to tax havens.

Special Considerations
Due largely to international pressure and the publicity surrounding the use of double Irish with a Dutch sandwich, the Irish finance minister passed measures to close the loopholes in the 2015 budget. The legislation effectively ends the use of the tax scheme for new tax plans. Companies with established structures were able to benefit from the old system until 2020.

Requirements for Double Irish With a Dutch Sandwich
The first Irish company would receive large royalties from sales sold to U.S. consumers. The U.S. profits and therefore taxes are dramatically lowered and the Irish taxes on the royalties are very low. Due to a loophole in Irish laws, the company can then transfer its profits tax-free to the offshore company, where they can remain untaxed for years.

The second Irish company is used for sales to European customers. It is also taxed at a low rate and can send its profits to the first Irish company using a Dutch company as an intermediary. If done right, there is no tax paid anywhere. The first Irish company now has all the money and can again send it onward to the company in the tax haven.

Example of the Double Irish With a Dutch Sandwich
In 2017, Google reportedly transferred 19.9 billion euros or roughly $22 billion through a Dutch company, which was then forwarded to an Irish company in Bermuda. Companies pay no taxes in Bermuda. In short, Google's subsidiary in the Netherlands was used to transfer revenue to the Irish subsidiary in Bermuda.
 
Google will finally stop using controversial Irish and Dutch tax loopholes




The era of Google using a pair of controversial loopholes to save billions of dollars in taxes on overseas ad revenue is coming to a close, according to a new report from Reuters. In 2020, the company will no longer take advantage of the so-called “Double Irish” and “Dutch sandwich” loopholes, which allowed it and countless other corporations to shift money from Ireland to the Netherlands and Bermuda, sheltering billions from taxes in the process.

The move comes as regulations aimed at changing how companies skirt taxes take effect in both the US and Ireland. Previously, multinational organizations like Google were able to use a network of affiliate organizations located in Ireland, the Netherlands, and Bermuda to collect and hold money made overseas, thanks in large part to lenient Irish tax laws.

GOOGLE USED COMPANIES IN IRELAND, THE NETHERLANDS, AND BERMUDA TO COLLECT AND HOLD MONEY EARNED OVERSEAS
The name comes from the strategy of moving money from an Irish subsidiary to a Dutch holding company, and then back to an Irish shell company located in Bermuda that has the rights to license Google intellectual property, thus the “Dutch sandwich” in between. Bermuda has no corporate income tax, making it a lucrative final stop to report income. The whole process effectively avoids paying US income tax and European withholding taxes on overseas profits, although some money is still paid to the Irish government.

In 2014, facing mounting pressure from the EU and the US, Ireland closed these loopholes. Companies were given until 2020 to comply with the new regulations, which is why Google is just changing its tax structure now. Google continued to use the tax scheme to funnel money around the globe until the deadline. According to Reuters, the company moved $23 billion to Bermuda in 2017 alone using this tax avoidance strategy.

In the US, the Trump administration has also tried to incentivize companies to return profits to the US by lowering the corporate tax rate from 35 percent to 21 percent. The Tax Cuts and Jobs Act of 2018 allowed companies to return money made overseas to the US without facing more US taxes. These changes could prove critical for Google, which is sitting on tens of billions in overseas earnings.

“We’re now simplifying our corporate structure and will license our IP from the US, not Bermuda,” a Google spokesperson told The Verge. “Including all annual and one-time income taxes over the past ten years, our global effective tax rate has been over 23%, with more than 80% of that tax due in the US.”
 
Apple and Amazon push to keep their tax breaks. France says 'non.'


For years, the U.S. tech giants have played a cat-and-mouse game with the U.S. and Europe over billions of dollars in taxes.

So far, the tech giants have won.


Despite their best efforts, European and American politicians have been unable to close the tax loopholes that allow Google, Facebook, Amazon and other companies to hang on to the vast majority of their earnings. The companies and their tax experts have used a list of evolving strategies with exotic names such as the “Double Irish,” the “Dutch Sandwich” and more recently the “Single Malt” and the “Green Jersey” to significantly cut down their tax liabilities.

“Every time I learn more and learn the strategies, I’m just blown away,” said Alexandra Thornton, the senior director of tax policy for economic policy at the Center for American Progress, a left-leaning think tank in Washington.

“There are such smart tax people that have devoted their careers to helping companies in a quote-unquote legal way.”

But the game is not over. France is preparing a new digital tax that will go into effect on Oct. 1, raising potentially hundreds of millions of euros for the country every year. It’s an approach that has already galvanized U.S. opposition from tech companies, politicians and even tax proponents who worry that a piecemeal approach will make it harder to solve the problem comprehensively.

France’s so-called GAFA tax, a reference to Google, Amazon, Facebook and Apple, charges a 3 percent tax on any company that has a global revenue of more than 750 million euros ($832 million) and at least 25 million euros (about $28 million) of revenue in France.

The aim of the new policy is to lessen large companies’ long-standing practice of legally and substantially reducing their tax burden by moving billions of dollars of revenue through various subsidiaries and other legal entities often in other tax-friendly countries and jurisdictions.

The tax is enough of a threat to have elicited a response from the U.S. tech industry. On Monday, tech lobbying groups and some companies testified before the Office of the United States Trade Representative that this new tax is unfair. The tax has also caught the attention of President Donald Trump, who in July threatened to tax French wine in retaliation.

Despite the pushback, it is still not clear how effective such a tax plan will be in raising money directly from these massive corporations. Amazon said in a recent filing that it is planning to pass along this 3 percent tax on to its sellers, who may in turn pass it on directly to consumers. The French government has claimed that consumers will not be affected by the new tax.

“Amazon, to the extent they have market power, can push it to someone else,” said Mark Mazur, the director of the nonpartisan Tax Policy Center, who formerly served as the assistant secretary for tax policy at the Treasury Department during the Obama administration.

Europe is not alone in trying to figure out a way to extract more tax dollars out of tech companies.

For more than five years, governments around the world — primarily at the Organisation for Economic Co-operation and Development (OECD), a Paris-based research group representing mostly advanced economies — have been trying to come up with a set of rules that would mitigate the practice of profit shifting.

And the U.S. has also been flummoxed by tech tax strategies. In a 142-page report in 2013, a Senate subcommittee concluded that from 2009 to 2012 Apple used loopholes to shift “$74 billion in worldwide sales income away from the United States to Ireland where Apple has negotiated a tax rate of less than 2 percent.” Much of its so-called offshore income, which is kept in American banks, is used to “minimize its corporate tax liabilities.”

Likely as a result of scrutiny by American and European lawmakers, Apple has subsequently modified its financial strategy to what has been dubbed the “Green Jersey,” as Apple moved its overseas cash stash to be “resident” in the Island of Jersey, a British crown dependency. A 2018 study by the European United Left party found that Apple may have paid as little as 0.7 percent tax in the European Union from 2015-17.

But with little in terms of global success, France has struck out on its own. Brad W. Setser, a fellow at the Council on Foreign Relations, and another former Treasury official during the Obama administration, said the taxes that companies like Apple do pay are “abusively low, and so it invites things like the French tax.”

Indeed, tech giants now fear that if France’s tax is successful, other countries will follow suit and will impose a similar tax.

Google’s top trade lawyer, Nicholas Bramble, wrote in a filing last week that if other countries follow France’s lead, “a series of cascading unilateral measures would have dangerous repercussions for the OECD’s multilateral process and for a wide range of U.S. export sectors.”

Mazur, the former Obama-era tax official, said that a consistent, international approach would be best, but that there’s little chance the Organisation for Economic Co-operation and Development, will be able to come to an agreement anytime soon.

And with companies able to pay top-dollar for tax lawyers, even national governments that can move faster than the OECD face a notable disadvantage, he said.

"What’s likely to happen is that a lot of countries doing things individually, independently, until that ticks off enough countries’ taxpayers and individuals, and they’ll figure out something else,” Mazur said. “The companies will almost certainly move faster than the government.”
 
Lord Nemesis said:
Where the loopholes for extra regular niggas?
Click to expand...
First you need to understand the entities--

US company US1 (this is typically the original entity)
Irish Company IR1
Irish Company IR2
Netherland Company NE
Tax Haven Company TH (could be any country with no corporate tax, but typically is one of the Caribbean islands)

US1 transfers property to IR1 (works best with intellectual property because of flexibility in valuing and ease of transferring ownership of intellectual property.)

US1 makes sales to customers in United States and collects revenue

US1 pays royalties to IR1 for use of intellectual property that was transferred to IR1 which moves most of its profits to IR1, because royalties for use of property are a legitimate business expense under US law. so the royalty payments reduce US1's taxable income.

Because of the way Irish tax law works if IR1, which receives all its income from overseas is controlled by managers from outside Ireland, then the profits in IR1 can be transferred tax free to any other country, so the profits go out to TH which is the manager of IR1. TH does not pay corporate income tax because it is located in a tax haven country.

IR2 is to make sales to customers in countries other that the US, because of Irish tax treaty with the Netherlands profits can be transferred tax free to NE which then can transfer profits tax free back to IR1 whose earnings end up in TH which pays no corporate income tax.

If US1 wants to repatriate the earnings that are stuck over in TH, then they either have to pay tax on those earnings or there are ways to use those funds to finance acquisitions which avoids repatriation tax.
 
DOS_patos said:
First you need to understand the entities--

US company US1 (this is typically the original entity)
Irish Company IR1
Irish Company IR2
Netherland Company NE
Tax Haven Company TH (could be any country with no corporate tax, but typically is one of the Caribbean islands)

US1 transfers property to IR1 (works best with intellectual property because of flexibility in valuing and ease of transferring ownership of intellectual property.)

US1 makes sales to customers in United States and collects revenue

US1 pays royalties to IR1 for use of intellectual property that was transferred to IR1 which moves most of its profits to IR1, because royalties for use of property are a legitimate business expense under US law. so the royalty payments reduce US1's taxable income.

Because of the way Irish tax law works if IR1, which receives all its income from overseas is controlled by managers from outside Ireland, then the profits in IR1 can be transferred tax free to any other country, so the profits go out to TH which is the manager of IR1. TH does not pay corporate income tax because it is located in a tax haven country.

IR2 is to make sales to customers in countries other that the US, because of Irish tax treaty with the Netherlands profits can be transferred tax free to NE which then can transfer profits tax free back to IR1 whose earnings end up in TH which pays no corporate income tax.

If US1 wants to repatriate the earnings that are stuck over in TH, then they either have to pay tax on those earnings or there are ways to use those funds to finance acquisitions which avoids repatriation tax.
Click to expand...

Lol bro he said extra regular niggas. That means regular niggas but more even more regular. This doesn't look like its for them blood
 
DOS_patos said:
First you need to understand the entities--

US company US1 (this is typically the original entity)
Irish Company IR1
Irish Company IR2
Netherland Company NE
Tax Haven Company TH (could be any country with no corporate tax, but typically is one of the Caribbean islands)

US1 transfers property to IR1 (works best with intellectual property because of flexibility in valuing and ease of transferring ownership of intellectual property.)

US1 makes sales to customers in United States and collects revenue

US1 pays royalties to IR1 for use of intellectual property that was transferred to IR1 which moves most of its profits to IR1, because royalties for use of property are a legitimate business expense under US law. so the royalty payments reduce US1's taxable income.

Because of the way Irish tax law works if IR1, which receives all its income from overseas is controlled by managers from outside Ireland, then the profits in IR1 can be transferred tax free to any other country, so the profits go out to TH which is the manager of IR1. TH does not pay corporate income tax because it is located in a tax haven country.

IR2 is to make sales to customers in countries other that the US, because of Irish tax treaty with the Netherlands profits can be transferred tax free to NE which then can transfer profits tax free back to IR1 whose earnings end up in TH which pays no corporate income tax.

If US1 wants to repatriate the earnings that are stuck over in TH, then they either have to pay tax on those earnings or there are ways to use those funds to finance acquisitions which avoids repatriation tax.
Click to expand...
Fam , I need you to break it down for me like I'm the cat that was in the class that all stayed inside for 5 periods got out for lunch then went back to the classroom in high school! My tax lady tell me every year I need to start a business to offset having no dependents but that's easier said than done when I'm working 60 plus hours a week at the gig and have a life outside of work. Where's the how to get the IRS off my back for dummies :the doing aight but far from rich nigga edition
 
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