If Google could find a way to legally sell babies to a food processor, should they pursue it if it increased value for shareholders?
Companies make choices, and they should not only be guided by money and what they can get away with. Google is fleecing US and European tax payers, and it's unethical.
If they were worried about staying competitive, they could lobby to close these loopholes, rather than simply take advantage of them.
Nobody really wants to pay more tax than required and it seems like google did check with the IRS for a decision prior to setting up the arrangement (usually these types of strategies are expensive to setup so paying the IRS for a ruling ahead of time is a good strategy). It reads like they pushed the limits though of the strategy and so got the IRS attention. I don't really fault them much - IRS letter rulings aren't cheap - and it's easy - much easier than most people think - to go a foul of tax rules. Much worse in my books are companies or individuals that have offshore entities that are used to hide income. So if I setup an offshore entity and shift my investments there - any income earned is still taxable in the US - but I simply do not report the income and if no tax reporting treaty is in place, then I have successfully dodged the IRS. This is clearly illegal. These sorts of shelters are used for hiding assets from angry ex-spouses and so forth as well which is also very questionable.
I might be old fashion or a socialist or communist or something, but I believe a company shouldn't work to dodge the taxes of the country it is founded in. If Google does not like the tax policy, they can lobby against it. Entertaining this Irish strategy is not admirable, and it hurts US citizens. Google would not exist but for an infrastructure built with US tax dollars. This behavior might be legal. It might be strategic. But it is unethical and driven by greed.
Honestly, when I was a young-in, tax avoidance (not evasion!) was heavily emphasized in my corporate tax classes - that makes sense as many would go to practice tax at a big accounting firm. Many of the big firms specialize in tax planning and avoidance which is why big companies hire them. If I were design a corporate tax structure (and be the excellent benevolent dictator that I would be), there are a few ground rules: (1) The tax base should correspond to global, financial based accounting income (2) Income should have the same taxablity regardless of corporate vehicle - profits in a llc should taxed the same as those of a c-corp (3) Tax rates should be progressive with very small businesses paying very low tax rates to spur mom&pop type businesses as well as entrepreneurial activity (4) Simple incentives for hiring additional people, R&D activity, and investing in equipment (5) A partial credit for foreign taxes paid (to try to keep double taxation reigned in) I've been thinking about this topic quite a bit. In Mexico, the law is that companies must pay out a certain portion of their profits to the employees. So the way that many of the larger companies avoid paying out this fee is that they form two umbrella corporations. The first corporation is the operating company that sells product and does all of the real work. The second is a kind of service company that hires almost all of the employees and essentially rents them to the operating company at a minimal margin. Since the most of the employees work for the services company, they are only entitled to a portion of the profits of the service company which has very little profit. Thus the law is circumvented. See pages 16 and 17 here http://www.lcilaw.com/QuickGuideMexico.pdf It's frustrating to me that the law is dodged in this fashion given the powerful impact that the law could have and was intended to have for employees in Mexico. (This is much longer than I intended to go on - tax and government regulation are areas that I'm rather passionate about)
That's not so true of Google as it is of other brass plate companies. Apple and Google operate offices here, but there are lots of companies that have one or two staff on the rolls and just funnel the money through Ireland without doing anything.
Unfortunately it's not going away soon as it's the only thing keeping Ireland afloat right now and the only way the economy is going to grow and the only way IMF money will get paid back, so there's no will to change the status quo.
I hear you. But, that status quo might be getting an update... http://www.sfgate.com/cgi-bin/article.cgi?f=/g/a/2011/11/08/... IMHO it seems very likely that the IMF's needs will far outpace it's ability to get paid.
* The country is planning an additional 12.4 billion euros ($17.1 billion) of austerity measures over the next four years* Or why I won't be working in Ireland…
Is the Euro that beneficial? Maybe not, but the EU is for Ireland, and staying in the EU is worth it in the eyes of a lot of people. Ireland was (and in a lot ways still is) a bit of a backwater and it was EU membership that really bucked that trend. And I don't think anyone sees us getting out of this on our own either, so we're doing what we're told. We do make our best art in times like these, so there is that… Ireland's in a weird place right now, the economy grew last quarter ahead of expectations but so did unemployment. What'll happen next, who knows?
:) I saw Martin McDonagh's play The Cripple of Inishmaan not too long ago here in Ann Arbor, (near Detroit, Michigan), and it was fantastic. A week ago I saw Beckett's Watt and Endgame at the same theater, back to back. Watt was pretty good, but I couldn't take Endgame. Being from Detroit, I can empathize with the feeling that a bit of hard times makes for great art. The city is pretty awful to live in, but it's very creative. Ireland's in a weird place right now, the economy grew last quarter ahead of expectations but so did unemployment. What'll happen next, who knows? That seems to be a theme. The US economy seems like some guy that just stood up after getting hit in the head. It looks like he might be ok, then he wobbles, then he steadies himself, then he wobbles again...