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Thanks to Obamacare Pfizer Relocating to Ireland

Liberalism would work so well if only people and companies would STAY put...pay the damn taxes...and just accept having less for themselves. If only they'd do that.
 
With $160 billion merger, Pfizer moves to Ireland and dodges taxes
Its executive offices (and major tax obligations) remained here in the US.-

The $160 billion merger, officially announced Monday, will allow Pfizer to move its executive offices to Ireland, thus lowering its tax rate, while also morphing into the world’s largest drug maker.


Pfizer, which was founded in Brooklyn, USA in 1849, began operating in Ireland in the 1960s.







http://pfizercareers.com/career-types/locations/ie
 
Smart business move. If politicians dont like it, make it more attractive for them to stay. Simple.
 
Pfizer isn't going to Ireland because of Obamacare.

They're going there because of high corporate taxes.

This is a "tax inversion" deal.

De facto, Pfizer isn't being purchased by Allergan. Pfizer is the buyer.

But because of the tax laws, Pfizer is doing a reverse merger and effectively taking over Allergan while relocating their HQ.
 
Pfizer isn't going to Ireland because of Obamacare.

They're going there because of high corporate taxes.

This is a "tax inversion" deal.

De facto, Pfizer isn't being purchased by Allergan. Pfizer is the buyer.

But because of the tax laws, Pfizer is doing a reverse merger and effectively taking over Allergan while relocating their HQ.
Obamacare taxes medical device manufacturers.
But either way, Democrat taxes have once again cost millions in tax revenue and jobs.
 
Pfizer isn't going to Ireland because of Obamacare.

They're going there because of high corporate taxes.

This is a "tax inversion" deal.

De facto, Pfizer isn't being purchased by Allergan. Pfizer is the buyer.

But because of the tax laws, Pfizer is doing a reverse merger and effectively taking over Allergan while relocating their HQ.

QFT.
 
Pfizer isn't going to Ireland because of Obamacare.

They're going there because of high corporate taxes.

This is a "tax inversion" deal.

De facto, Pfizer isn't being purchased by Allergan. Pfizer is the buyer.

But because of the tax laws, Pfizer is doing a reverse merger and effectively taking over Allergan while relocating their HQ.
is this the reason?
Double Irish arrangement - Wikipedia, the free encyclopedia


Double Irish arrangement
The double Irish arrangement is a tax avoidance strategy that some multinational corporations use to lower their corporate tax liability. The strategy uses payments between related entities in a corporate structure to shift income from a higher-tax country to a lower-tax country. It relies on the fact that Irish tax law does not include US transfer pricing rules.[1] Specifically, Ireland has territorial taxation, and hence does not levy taxes on income booked in subsidiaries of Irish companies that are outside the state.

The double Irish tax structure was pioneered in the late 1980s by companies such as Apple Inc..[2] In 2010 a law intended to counter such arrangements was passed,[where?] though existing arrangements were exempt and lawyers have said that this change will cause no significant problems for multinational firms.[3]

In 2013, the Irish government announced that companies which incorporate in Ireland must also be tax resident there. This counter-measure took effect in January 2015, for newly-incorporated companies, and will take effect in 2020 for companies with existing operations in Ireland.[4] Irish Finance Minister Michael Noonan, during the presentation of his 2015 budget, said that he believed this would align Ireland's corporate tax regime with international best practice.[5]

Overview
Typically, the company arranges for the rights to exploit intellectual property outside the United States to be owned by an offshore company. This is achieved by entering into a cost sharing agreement between the US parent and the offshore company, written strictly in terms of US transfer pricing rules. The offshore company continues to receive all of the profits from exploitation of the rights outside the US, but without paying US tax on the profits unless and until they are remitted to the US.[6]

It is called double Irish because it requires two Irish companies to complete the structure. One of these companies is tax resident in a tax haven, such as the Cayman Islands or Bermuda. Irish tax law currently provides that a company is tax resident where its central management and control is located, not where it is incorporated, so that it is possible for the first Irish company not to be tax resident in Ireland. This company is the offshore entity which owns the valuable non US rights that are then licensed to a second Irish company (and this one is tax resident in Ireland) in return for substantial royalties or other fees. The second Irish company receives income from the use of the asset in countries outside the US, but its taxable profits are low because the royalties or fees paid to the first Irish company are tax-deductible expenses. The remaining profits are taxed at the Irish rate of 12.5%.

For companies whose ultimate ownership is located in the United States, the payments between the two related Irish companies might be non-tax-deferrable and subject to current taxation as Subpart F income under the Internal Revenue Service's Controlled Foreign Corporation regulations if the structure is not set up properly. This is avoided by organizing the second Irish company as a fully owned subsidiary of the first Irish company resident in the tax haven, and then making an entity classification election for the second Irish company to be disregarded as a separate entity from its owner, the first Irish company. The payments between the two Irish companies are then ignored for US tax purposes.[1]

Dutch sandwich


Example of a double Irish with a Dutch sandwich:
1. An advertiser pays for an ad in Germany.
2. The ad agency sends money to its subsidiary in Ireland, which holds the intellectual property (IP).
3. Tax payable in Ireland is 12.5 percent, but the Irish company pays a royalty to a Dutch subsidiary, for which it gets an Irish tax deduction.
4. The Dutch company pays the money to yet another subsidiary in Ireland, with no withholding tax on inter-EU transactions.
5. The last subsidiary, although it is in Ireland, pays no tax because it is controlled outside of Ireland, in Bermuda or another tax haven.
Ireland does not levy withholding tax on certain receipts from European Union member States. Revenues from sales of the products shipped by the second Irish company (the second in the double Irish) are first booked by a shell company in the Netherlands, taking advantage of generous tax laws there. Overcoming[clarification needed] the Irish tax system, the remaining profits are transferred directly to Cayman Islands or Bermuda. This part of the scheme is referred to as the "Dutch sandwich".[7][8] The Irish authorities never see the full revenues and hence cannot tax them, even at the low Irish corporate tax rates.

Countermeasures
In 2010, the Obama administration was said to propose to tax excessive profits of offshore subsidiaries to curb tax avoidance in the United States.[9] A 2010 Irish law brought Ireland into line with most of its trading partners by introducing a formal regime requiring companies' intra-group transfer prices to be similar to those that would be charged to (or from) independent entities. The first deadline for corporate tax submissions under the new rules was September 2012.[3] However, companies such as Google, Oracle and FedEx are declaring fewer of their ongoing offshore subsidiaries in their public financial filings, which has the effect of reducing visibility of entities declared in known tax havens.[10]

In 2014, the Irish government announced that companies would no longer be able to incorporate in Ireland without also being tax resident there, a measure intended to counter arrangements similar to the double Irish.[4] Irish Finance Minister Michael Noonan addressed the "Double Irish" during the presentation of his 2015 budget. Under the new rules, companies not already operating in the country may not pursue the “Double Irish” scheme as of January 2015; those already engaging in the tax avoidance scheme have a five year window until 2020 to find another arrangement.[11]

Companies using the arrangement
Major companies known to employ the double Irish strategy include:

  1. Abbott Laboratories[12][13]
  2. Adobe Systems[14]
  3. Apple Inc.[2]
  4. Eli Lilly and Company[14]
  5. Facebook[9]
  6. Forest Laboratories[14]
  7. General Electric[9]
  8. Google[9][14][15]
  9. IBM[16]
  10. Johnson & Johnson[9]
  11. Microsoft[14]
  12. Oracle Corp.[14]
  13. Pfizer Inc.[14]
  14. Starbucks[9]
  15. Yahoo![17]
 
I bet you fools believe American pharmaceuticals are made in America...
48 Pharma companies within an hour of my house.

HQs, maybe. Manufacturing plants, doubtful.

Unless you live in China or India.
Many manufacture. Google San Diego.
But Democrats have them fleeing, so in a few years you'll be right.

Biotech's a niche market.

The others have been "fleeing" for the reasons Toro mentioned...and for a very long time.

If you're trying to retcon history, you should at least try for credibility.
 
I bet you fools believe American pharmaceuticals are made in America...
48 Pharma companies within an hour of my house.

HQs, maybe. Manufacturing plants, doubtful.

Unless you live in China or India.
Many manufacture. Google San Diego.
But Democrats have them fleeing, so in a few years you'll be right.

Biotech's a niche market.

The others have been "fleeing" for the reasons Toro mentioned...and for a very long time.

If you're trying to retcon history, you should at least try for credibility.
All fleeing because of regulations and taxes have forced them to leave.
You somehow keep wanting to not mention that FACT.
 
Pfizer isn't going to Ireland because of Obamacare.

They're going there because of high corporate taxes.

This is a "tax inversion" deal.

De facto, Pfizer isn't being purchased by Allergan. Pfizer is the buyer.

But because of the tax laws, Pfizer is doing a reverse merger and effectively taking over Allergan while relocating their HQ.
Obamacare taxes medical device manufacturers.
But either way, Democrat taxes have once again cost millions in tax revenue and jobs.

Pfizer manufactures pharmaceuticals, not medical devices.
 

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