2011年4月8日星期五

Wanted: A Tax Code for the digital age

By Alison Fitzgerald and Catherine DodgeE:\GG工具\GG发布\data\becauseofafailed\2\1116_mz_b5bgovtarget.jpg

Illustration by Carlos Monteiro

Anyone who wishes a console Nintendo Wii or the latest John Grisham novel can pick up at the store of the nearest target (TGT) or log on Amazon.com (AMZN) and have delivered. The similarities between the two retailers are not obvious when it comes to taxes. Amazon - the total effective rate she pays in taxes on the income of federal, State, and international after deductions, with its sales and royalties from property - and since more than 10 percentage points lower than the target of the last four years. Effective tax rate of the target in 2010 has been 35.1%, compared to 23.5% Amazon. Amazon in 2010 to $ 352 million in income taxes in the world on the income of $ 1.5 billion, according to its SEC filings, so that the target to 1.58 billion on revenue of $ 4.5 billion. Amazon, the largest worldwide online retailer, has successfully resisted the efforts of politicians to levy taxes to State and local who must charge the brick and mortar rivals. Tax laws "absolutely" make target disadvantage, explains Brian Sozzi, an analyst with strategies of Wall Street in New York. "It is one of the reasons why Amazon has been such a success."

These businesses are an example of how the U.S. corporate tax code promotes global companies by domestic ones, high technology firms report more old-school manufacturers and cash on the oil companies. The rate of U.S. federal tax of 35 percent is highest in developed countries. Still, the Treasury Department says that the Federal Government was bleeding $ 1.2 billion in a decade as battalions of lobbyists, accounting, and lawyers create and promote other ways to avoid taxes.

This state of fact increased a political process where companies and their professional associations guide money campaign to legislators who write in special tax legislation breaks for favored industries. "Tangling" is that George k. Yin, a former Chief of staff for the joint Congressional Committee on taxation, and now a Professor of law at the University of Virginia, calls in the tax code. "It's a very complicated society and economy that we live." You add to this the fact that we are not all politicians with pure hearts and minds. "And then you have all the different interest groups." Put it all together and what get you? A 5,000 page document which, in printed form, weighs approximately nine pounds - as a big baby.

The tax code of the United States was written at a time when American companies dominate the world economy and Internet did not enter the imagination of scientists of the Department of defence. Major rewrite last there is a quarter of a century did not change the basic structure, the business taxes on income in the world that when they bring home overseas profits. "We have a lot of tax preferences reduce the effective rate", explains Ed Kleinbard, Professor of tax law at the University of Southern California and a former Chief of staff of the Joint Committee on taxation. These preferences "distort decisions and imperfectly are widespread in the business sector."

The effect of the tax on the behaviour of the company code is clear when comparing the target and Amazon. Amazon, based in Seattle and founded in 1995, made a series of blows to reduce its tax bill because it became profitable in 2005. That same year it established a European seat in Luxembourg, where the rate of the corporate income tax is 21%. The following year the company paid an effective tax rate of 49.6% of a sale of property to its Luxembourg subsidiary, according to its deposits of the Securities and Exchange Commission. Since 2007, the effective tax rate of the Amazon has ranged from 27.9% to 21.9%. Amazon executives refused to be interviewed.

By moving intangible assets such as patents and intellectual property in the Netherlands tax, Amazon could then pay affiliates in these countries for the use of the assets, cut its revenue in high-tax jurisdictions. The practice, known as prices, transfer is a common strategy for global companies employ to reduce taxes. These techniques "are not easily accessible to purely national companies, explains Sullivan."

Amazon did not disclose its corporate deposits exactly what elements of assets, he moved to other locations. However, the company owns 253 Americans and 39 U.S. trademarks, patents database online US patent and Trademark Office. The patents include several for its Kindle electronic reader and recommendation system.


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