Burger King
- Thread starter GURPS
- Start date
Sorry...your facts are incorrect (that's not unusual is it?)
http://econospeak.blogspot.com/2014/08/burger-king-inversion-dealbook-misses.html
You also seem to not understand that it takes two sides to actually fix something that everyone agrees is broken. When NEITHER side will speak to the other, nothing gets done.
so a 7% or higher tax savings .... still a good reason for the change, and still shows Canada has a lower Corp Tax Rate that the US
so sweetie, how do you propose lowering the Corp Tax Rate - since progressives love to demonize companies for making money - unless they support progressive causes
Grumpy
Well-Known Member
Think he misunderstood and told another whopper instead.
LibertyBeacon
Unto dust we shall return
Funny how "corporation people" can move to another country to avoid taxes, but not "regular people", eh?
When the left consists of mentally unbalanced folks like you and Krugman...what else could the outcome possibly be, sweetie?
Tilted
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No, I don't think this should be seen as a big FU to President Obama. This deal isn't being done purely (or primarily) for tax advantages. This is a deal that makes sense to the respective companies for other reasons. Wanting to, in effect, merge for other reasons they of course then had to decide where the new company would be based. Corporate tax policies surely played a roll in that decision, but there are other reasons why Canada probably makes more sense. It isn't like the dog is wagging the tail here, Tim Hortons a similarly sized company (and by revenue it's substantially bigger than Burker King, though that's a bit misleading because Burger King is almost entirely a franchiser at this point). And Tim Hortons is more significant to Canada than Burker King is to the U.S., it's the big dog in Canada - they likely wouldn't have been to oo keen on it becoming a foreign company. Would they have blocked the deal had the U.S. been the planned new home? I don't know, but it seems possible to me.
But to touch on the tax ramifications briefly, it isn't so much the difference in rates that's important - it's the reality that Canada (like most of the economically advanced world these days) doesn't use an absurd worldwide corporate income taxation system like the U.S. still does, Canada has a territorial taxation system. In other words, if a company domiciles in Canada it is allowed to bring money into Canada - money that can, e.g., be used to pay dividends or make capital investments or otherwise injected into the Canadian economy (and which can ultimately increase the Canadian tax base) - without having to pay a huge 'bring your money here' fee. If a company is domiciled in the U.S., it isn't allowed to bring money (that was made elsewhere) here without having to pay such a fee. We presume to tax income and economic activity regardless of where in the world it happens. Deciding to have the new company domiciled in Canada doesn't primarily benefit that new company because of a difference in the tax rates, it benefits the company because of the difference between a worldwide and a territorial tax system. Income made in the U.S. is still taxed at U.S. rates, income made in Canada is still taxed at Canadian rates, and income made in other countries is still taxed at their rates, regardless of where the company is domiciled. The difference is being able to bring foreign after-tax profits home such that they, among other things, benefit the domestic economy.
Part of the reason for this (effective) merger is to help Tim Hortons expand internationally. To the extent it is going to be able to do that, it makes sense that the new company wouldn't want to burden that expansion by creating new (crazy ass and improper) taxation on the income generated by that expansion by moving Tim Hortons' headquarters to the United States. But this deal isn't the kind of tax inversion that has been in the news lately - Burger King didn't find some smaller company that it could acquire mostly so that it could move its home to a foreign, more tax friendly, country.
Tilted
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Regular people can move (i.e. change their citizenship) and thus avoid extraterritorial taxation (again, these moves aren't about avoiding taxation on income earned in a given country - i.e. in the country that was previously 'home').
If your point is that moving for a person means something different than it does for a corporation then... of course it does. That's because of the nature of a corporation as compared to that of an individual person. A corporation can (and most do) exist in many places at the same time. It isn't a single person or a single entity, it is all kinds of things and people and locations and property and activities - often spread out and going on all over the place simultaneously.
More importantly though, corporations' activities inure to the benefit of "regular people". It is some collection of such regular people that enjoy the benefits of corporations being able to move to countries that - as demonstrated by their different policies - want those corporations to domicile there. It is regular people who, ultimately, end up losing less of their money to taxation - who, in effect and in the end, are taxed less - when corporations move to countries with more sensible taxation policies.
Tilted
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What aspect of the argument? I have plenty of thoughts on the general notion, but give me a bit better idea what you're asking me about and I'll (hopefully) be able to give you a more focused and thus responsive answer.
EDIT: I guess I can throw out a few general thoughts even without more focus guidance from you.
One thing I'd point out is that people too often gloss over (or rhetorically ignore) this simple reality of existence: Things can be quite alike in certain ways even while they're quite different in others. Indeed, that's the nature of the Universe. Everything is like everything else in certain ways and different than everything else in other ways. Trees are like flowers, except to the extent they're not. The same with rocks and flowers. When you're considering whether various things are alike for certain purposes or in certain ways, the point that they aren't alike in other ways doesn't necessarily meaningfully inform the consideration. I don't need to demonstrate that corporations and individual people are the same in ways X, Y, and Z to persuasively argue that it makes sense to treat them much the same when it comes to purpose A.
Another point is this, assuming part of what you're getting at is people's consternation that corporations are generally regarded as having rights and being protected by various constitutional provisions: I don't think people that argue that they shouldn't be so regarded follow the thought process through enough. They don't apply common sense, they don't consider what it would mean - for practical purposes, in real world terms - if we took the general position that corporations (or human activity that occurs through corporations or under the shell of incorporation that we've conceived) don't enjoy many of the same rights that individual people do. That position would be very problematic, for actual people not just for corporations. It would be actual people whose rights were left unprotected. Government could do what it wanted to newspapers, TV stations, churches - it could trample on the most basic rights that we've come to assume we enjoy. If you want examples I'll provide them - they're essentially countless, and many would be quite unacceptable to most people if they actually considered them.
Lastly, I'd say that the argument that I think you're referring to - the notion that corporations shouldn't enjoy many of the same protections that people do - relies in large part on an intellectual inconsistency. Beyond the practical aspect of the consideration that I alluded to in the previous paragraph, the position doesn't make logical sense if you break it down and think about the argument that's actually being advanced. I don't think most of the people taking that position do that, so they don't realize that in order for their position to make sense they have to argumentatively conceive of the corporate structure as very different things, while at the same time conceiving of it as neither of those things, in order to simultaneously sidestep the arguments that would doom their position logically. On the one hand they have to deny that the corporate form is one thing or their argument falls apart, and on the other hand they have to deny that the corporate form means another thing or else their argument falls apart for different reasons. But the thing is, the corporate form has to be one of those two things or some combination of them, there aren't any other possibilities. When we acknowledge that simple - and I believe irrefutable - reality, we're left with the understanding that it isn't really corporations that have the rights in question it is people acting through corporations that are just retaining the rights in question.
To go a little further with that final thought: One way to conceive of a corporation is as a group of people acting collectively. If someone doesn't want to conceive of it that way, fine - I won't quibble with them. But if it is people acting collectively, it's already apparent that it is actually those people's rights that are at stake and not the corporations. People generally retain their rights even when they act collectively because, for one thing, we enjoy a freedom of association. But what if we don't accept that conception of what a corporation is? if a corporation isn't people acting collectively then what is it? Well, it's something that isn't people, and that set of existence could be divided up into two subsets: (1) Things that exist without regard to human action and act other than by human control and (2) Things that exist by human action or act by human control. In other words, if a corporation isn't the people themselves then it is either something people create or use, or it is something that exists naturally and without human creation and isn't used by humans for their own ends. I'd hope we can all agree it isn't the latter. Corporations are things we create, and they have no interests except those that we impart to them, and they don't do anything except by human direction. A corporation doesn't do a single thing except by human action and in furtherance of human interest (intentionally or otherwise, prudently or otherwise, sensibly or otherwise). It is something we use. So, again, it's apparent that it is actual people's rights that are at issue. We might use a corporation to do something, but it is we who are doing it - it is we who want it to be done, who seek to benefit by it. We use paper and ink to convey information and thoughts, but it isn't the ink or paper's rights that are at issue, it is ours. We use things to achieve our ends, but it is us - people - who are the doers. It is us - people - who have rights that we shouldn't necessarily lose just because we have to use things to exercise them.
Summing up that little mental exploration: Corporations are either the people involved with them or they are something those people use. Or, and this is probably more fairly considered to be the case, they are some combination of those things. Either way, it is the people involved whose rights are in play - not the corporations. If we argue that corporations shouldn't enjoy certain rights what we are really arguing is that people should lose those certain rights either when they (1) come together to act or (2) use something to act. Now, if we want to make such an argument, fine - if we want to condition rights protections on whether people are acting collectively or on whether they use something other than themselves in acting, fine. But let's be intellectually honest about the position we're advancing. This isn't about not extending people's rights to cover corporations, this is about taking away people's rights because they act within the corporate context. There are some plausible, even reasonable, arguments for doing the latter in certain contexts. But in other contexts, those arguments fall flat.
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after reviewing the [very long] wikipedia article I see why you were a bit confused about my general question ....
I was thinking more about Progressive wailing and gnashing of teeth about 'Corp Personhood' ... since the CU case ....
what sprang to mind when you read my query [probably NOT the CU Decision]
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Tilted
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I just edited my previous post and added some general thoughts on the basic issue you're referring to.
I think much of the consternation is short-sighted and otherwise nonsensical. It's people not really thinking about things and then rhetorically taking a position the real world results of which they wouldn't likely support. In part it's a manifestation of the general excus-ism that pervades modern (and perhaps historical) political conversations. It's also part of the general dissonance between our collective abstract and rhetorical claims and our collective specific and actual wants. It's searching for, and pretending to slay, bogeymen so that we can sleep a little better at night. And that proverbial exercise is a poor, though all too common, substitute for the seemingly more difficult - or at least more involved and more committed - task of being the kind of person that can look themselves in the mirror at night, and truly liking who they see, sleep soundly even without having identified a few bogeymen.
I would never say people singularly or in a group [political party or group] should be denied the ability or right to donate time, or money to the congress critter of their choosing ....
if It cannot vote, it does not donate .... lobbying groups, corporations - because those people as individuals can vote / donate
