Could tax inversion work for tech companies?

‘Tax inversion’ mergers are an increasingly-popular way for multinationals to dodge their tax bills, by arranging to be taken over by a corporation in a lower-tax jurisdiction. Fruit of the Loom, for example, used this dodge to move to the Cayman Islands back in 1998.

In the current wave, a string of companies are queuing up to move to Ireland through tax inversions, with pharmaceutical companies being the largest among them. Here the FT looks at a current example, Abbvie (US) planning to merge with Shire (UK/Ireland)

Reading the FT’s commentary makes it painfully clear that there is little business logic to a deal like this, beyond the massive extra profits to be had from dodging tax. And despite the political unpopularity, the IRS hasn’t yet found a way to crack down on them.

All this makes me look at the tech sector in a new light. Companies like Google, Apple and Microsoft are hoarding huge piles of cash in their non-US subsidiaries. They’ll be liable for a massive tax bill once they bring it back to the US — which they will need in order to pay it out as shareholder dividends.

The general assumption is that they are waiting for some kind of tax break — if not a permanent change in the law, at least a one-off amnesty which will let them bring the money home. I’m now wondering, though, whether some of them are also contemplating a tax inversion. Move out of the US, then finally claim your profits and pay out dividends at a lower tax rate. This analysis suggests it’s likely, but has found no tech companies even hinting that they are contemplating it.

Searching overseas servers

Did you ever worry which jurisdiction a server was in? No longer. The US and UK have both decided they can demand access to data regardless of where in the world it is, writes Marcy Wheeler.

The UK version comes courtesy of DRIP, the surveillance bill being rushed through parliament to avoid awkward questions. The government’s defense, bizarrely, is that they have been doing this all along:

The home secretary told the Commons home affairs committee that it had always been assumed “in government circles” that the requirement on overseas companies to comply with British intercept warrants was included in the 2000 Regulation of Investigatory Powers Act.

In the US, the government has won a case forcing Microsoft to turn over data from Ireland:

the U.S. feels free to demand data from U.S. companies no matter where that data is stored. So while Microsoft’s challenge largely serves to make its legal obligations visible to the rest of the world, the legal case may have real consequences, both legally and economically.

So, in brief: wherever in the world your data is, it isn’t safe from hte UK or the US

770 migrants died this year, trying to reach the EU

So far this year, 770 migrants have died trying to reach Europe, or trying to stay here.

That’s an underestimate.

The Migrants Files contains the details. It’s an attempt to track all the deaths associated with migration in(to) Europe. The details make for sobering reading:

  • 25 migrants were locked up in a cold store by their traffickers in Libya. 13 died.
  • The 27 survivors of a shipwreck said there were an additional 75 persons on board.
  • A migrant was shot at Calais. No other details were provided by the police.
  • Stowaway fell from the wheelbay on a plane to Zürich.

It goes on, and on — 2780 incidents stretching back to 2000. 25,000 dead.

And, aside from the occasional media fuss, we don’t care. We don’t even know the names of most of the victims, let alone the circumstances which drove them to risk their lives in transit. The deaths aren’t being tracked officially — this is a database put together by journalists, mianly from news reports.

Quietnet

I’ve not tried this, but I like the concept. Quietnet connects two computers using their speakers, turning a text chat session into ultrasonic communication:

run python send.py in one terminal window and python listen.py in another. Text you input into the send.py window should appear (after a delay) in the listen.py window.


Warning

: May annoy some animals and humans.

Education of a prince

I’m enjoying The Sleepwalkers, Christopher Clark’s history of the start of the First World War. I may well not make it through all 700-odd pages, but so far he has an eye for the comically grotesque in early 20th century Europe.

So there’s the story of how a military officer nicknamed Apis, veteran of several regicidal plots, was trusted to look after the crown prince:

when King Petar looked in the winter of 1905 for a companion to accompany his son, Crown Prince Djordje, on a journey across Europe, he should choose none other than Apis, fresh from a long convalescence and still carrying three of the bullets that had entered his body on the night of the assassinations. The chief architect of the regicide was thus charged with seeing the next Karadjordjevic king through to the end of his education as prince. In the event, Djordje never became king; he disqualified himself from the Serbian succession in 1909 by kicking his valet to death

Hiding from the public

Good Yorkshire Rant on issues where the UK political parties are in agreement, and a majority of the population disagrees with them all.

It has been true, as long as there has been a privatised railway, that any British politician could do better in the polls by attacking it and by promising to reverse the privatisation….There is even a simple policy option available to make it happen: stop issuing franchises and just let them all revert. Yet no-one with any power has been willing to take the step of making this option available on the ballot. The political system’s role as a mechanism for limiting the agenda has rarely been more clear.

The parties doing well, UKIP and the SNP, are the ones breaking out of this consensus to avoid certain issues

Pool: a game all about stoning chickens

The Etymologicon is a wonderful book on English word origins. I thought I’d share one particularly hilarious bit: the origin of pool:

It starts with French gamblers. Apparently they would place bets on who was able to hit a chicken (poule) with a rock. Then:

The term got transferred to other things. At card games, the pot of money in the middle of the table came to be known as the

poule

. English gamblers picked the term up and brought it back with them in the seventeenth century. They changed the spelling to

pool

, but htey still had a pool of money in the middle of the table.



When billiards became a popular sport, people started to gamble on it, and this variation was known as

pool

, hence shooting pool.

Crystal meth in Tehran

Crystal meth is increasingly popular in Iran, reports the Guardian

Meth production in the country has been expanding at an astonishing rate

….

Research carried out by the State Welfare Organisation shows that over half a million Tehranis between the ages of 15 and 45 have used it at least once.

Meth is apparently less socially constrained than other drugs. Cocaine is for the rich, ecstasy is for teenagers, opium is for the elderly — but crystal meth is for everyone.

Clean blogging in Russia

Russia’s crackdown on bloggers includes an obscenity ban. From August, Russian blogs will be banned from using хуй (‘cock, prick’), пизда (‘cunt’), ебать (‘fuck’), and блядь (‘whore’). From the New York Times:

“We feel like we are back in kindergarten again when they said, ‘Don’t pee in your bed and don’t eat with your hands and don’t use that word,’ ” said Viktor V. Yerofeyev, a popular writer. “On the one hand, the Russian government says the Russian people are the best. On the other hand, it doesn’t trust the people.”

[via Language Hat]

Teaching Ovid, rape and all

Liz Gloyn worries how to teach the rapey bits of Classics — especially given that, statistically, it’s likely that some of her students will have been affected by sexual violence:

I have a pedagogical duty to frame those texts in ways which do not diminish them, do not side-line them or pretend they are not there. Ignoring the uncomfortable bits is not only lazy – it’s also potentially dangerous, because it does not challenge narratives which a feminist pedagogy should. It does not challenge students to read this material with a critical eye, to see what is actually going on in them – which is a skill we would expect them to demonstrate when reading any other text. Incidentally, it does also not require us to judge the ancient texts anachronistically. We are not asking the Romans to share our standards. What I am asking is that my students appreciate just how different these texts are from what we would see as socially acceptable, and to read them with that in mind.