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Burger King Should Not Be Condemned If It Moves To Canada For Tax Purposes

Burger King

The business and political worlds collided this morning when The Wall Street Journal reported that Burger King is apparently in talks to buy iconic Canadian coffee and doughnut chain and that the purchase as contemplated at least in part to avoid U.S. corporate taxes:

Burger King Worldwide Inc.  is in talks to buy Canadian coffee-and-doughnut chain Tim Hortons Inc., a deal that would be structured as a so-called tax inversion and move the hamburger seller’s base to Canada.

The two sides are working on a deal that would create a new company, they said in a statement, confirming a report on the talks by The Wall Street Journal. The takeover would create the third-largest quick-service restaurant provider in the world, they said.

Inversion deals have been on the rise lately, and are facing stiff opposition in Washington given that they threaten to deplete U.S. government coffers. A move by Burger King to seal one is sure to intensify criticism of them, since it is such a well-known and distinctly American brand.

A person familiar with the matter said a deal between the two companies could be struck soon, though additional details on timing couldn’t be learned. Tim Hortons has a market value of about $8.4 billion, while Burger King’s is about $9.6 billion, so together the restaurant companies are currently worth about $18 billion.

By moving to a lower-tax jurisdiction, inversion deals enable companies to save money on foreign earnings and cash stowed abroad, and in some cases lower their overall corporate rate. Even though many of the headline-grabbing inversion deals of late have involved European companies, Canada has also been the focal point for a number of them, given its proximity and similarity to the U.S. Canada’s federal corporate tax rate was lowered to 15% in 2012.

It’s worth noting that there are potential benefits to this deal to the new company that go beyond the tax advantages. Breakfast has become the fastest growing part of the fast food market in the United States, as evidenced most recently by Taco Bell’s entry into that line of business. Tim Horton’s has an excellent reputation in Canada and those parts of the United States where it has expanded for its coffee, donuts, and other products. Bringing that expertise into a fast growing market, and using Burger King’s much bigger franchise base to expand it, would seem to be a pretty smart business move.

However, it is the tax issue that is getting the most attention today.

As the Journal goes on to note, if this deal goes forward it would be the latest in a series of similar deals between American and Canadian companies that have been reached over the two years that the new Canadian tax rate has been in effect and, while its unclear exactly how much a move like this would lower Burger King’s tax liability in the United States it would most certainly put it somewhere below the effective 27% rate that it has been paying in recent years. One analyst estimates the potential tax savings for the new company as high as 13%.  On paper, the corporate tax rate is 35%, however due to subsidies, credits, and the manner in which taxable income is calculated few populations pay that as the effective rate on the entirety of the corporate income. Notwithstanding that, it is clear that most corporations pay an effective rate in the United States well above the rates that corporations in other parts of the world pay. This has resulted not only in the type of deal that Burger King and Tim Horton’s are contemplating, but also in the phenomenon of American corporations “parking” large amounts of profits earned overseas in foreign banks to avoid American taxes. Apple alone has $138 billion in overseas cash, and Microsoft is believed to have roughly $39 billion, while the entire amount of overseas cash held by American corporations is estimated to be nearly $2 trillion. This has led many analysts and politicians, mostly Republicans but also many Democrats, to suggest that the United States should consider reforming its corporate tax system to one with lower rates and fewer exemptions, deductions, and credits so as to attract foreign business and encourage American companies to bring some of that overseas cash home.

Not surprisingly, the reaction to the news of the Burger King from the usual suspect has been more about political demagogurey than a rational discussion of tax policy. Business Insider’s Joe Weisenthal, for example, called the proposed deal a direct challenge to the White House:

Tax inversions have been a big theme of 2014, as several companies (largely in the pharmaceutical space) have acquired foreign rivals to move their tax base elsewhere.

These deals have infuriated some in Washington, and the loss of an iconic brand only adds fuel to the fire. There has been talk of legislation to limit tax inversions, but in this political climate, the idea of anything actually passing both houses of Congress seems very slim. So earlier this month, the White House said it may use an executive order to limit tax inversions, though it remains unclear how much teeth any executive order would have.
Either way, this warning (or threat) apparently is not much of a deterrent to deals being commenced.

Greg Valliere of Potomac Research says that Burger King’s actions are a direct statement to the White House and the Treasury, basically daring them to back up their warning with action

(…)

Meanwhile, the news gives Democrats another talking point. The potential departure of an iconic American company because of “corporate greed” will be trotted out on the campaign trail.

Additionally, as Professor Bainbridge notes, there has been the expected reaction on Twitter from the usual suspects:

All of these responses, and more like them, are tinged more with moral resentment than any rational considerations of public policy. If companies like Burger King are considering inversion deals to save money, and others are parking trillions in cash overseas for the same reason, then the rational thing would be to look at our corporate tax laws and determine how we can change them to discourage this type of behavior. Many analyses have shown that reforms that lower rates while simultaneously cutting back on loopholes that are based more in political favoritism and crony capitalism than sound tax policy would actually increase tax revenues over time, just as gross tax revenues increased when rates were cut during the Reagan Era. Obviously, this would deprive the President and the Democratic Party of the political whipping boy that going after so-called “evil” corporations gives them, but if they really want to do what’s right for the country, which is why they were elected in the first place, then they’d put partistanship aside for once.

As for the ethics of what Burger King is planning here, that too is mostly nonsense. A corporation’s primary duty is to represent the best interests of its shareholders, within the bounds of the law. That is exactly what the corporation’s board is doing in this case. Reducing the company’s overall tax burden, while at the same time opening up potential new markets as noted above, is clearly in the company’s best interests and, indeed, the board would be acting irresponsibly if they rejected this deal because of social pressure from a bunch of morally preening people on Twitter who wouldn’t know how to operate a business if their life depended upon it.

Update: This tweet was deleted from the original post when the author pointed out that it was meant to be sarcastic, which I should have recognized.

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About Doug Mataconis
Doug holds a B.A. in Political Science from Rutgers University and J.D. from George Mason University School of Law. He joined the staff of OTB in May, 2010 and also writes at Below The Beltway. Follow Doug on Twitter | Facebook

Comments

  1. JWH says:

    I’d like a flame-broiled Whopper doughnut, eh?

    Like or Dislike: Thumb up 10 Thumb down 0

  2. Mu says:

    Are we still allowed to condemn BK for horrible food?

    Like or Dislike: Thumb up 14 Thumb down 1

  3. wr says:

    And by this “liberarian” reasoning, we shouldn’t condemn US intelligence officers who sell our secrets to the enemy,, because they are just following the dicates of the market.

    Remember, kids, the only thing that matters in life is that you amass as much money as humanly possible, no matter how many people you hurt or lives you destroy. It’s all about you and your pile of cash.

    Highly-rated. Helpful or Unhelpful: Thumb up 74 Thumb down 14

  4. Tony W says:

    Hear-ye, hear-ye. All Hail King Horton of Miami Winnipeg!

    Like or Dislike: Thumb up 3 Thumb down 0

  5. Perhaps instead of reflexively cursing out Burger King, we might consider if our corporate tax policy has become unnecessarily punitive when even CANADA starts looking like a tax haven.

    Hot debate. What do you think? Thumb up 19 Thumb down 18

  6. Tony W says:

    @Stormy Dragon: Perhaps instead of simply blaming tax policy we can take a harsher look at our true national religion – Capitalism, and consider whether some sort of patriotic response might be appropriate?

    Highly-rated. Helpful or Unhelpful: Thumb up 34 Thumb down 11

  7. Eric Florack says:

    @Tony W: the patriotic response would be the elimination of the policies that are damaging businesses. also the elimination of those who brought us said policies.

    when you tax the lifeblood out of businesses and make enemies of anyone with a profit motive, why on earth is anyone shocked when the economy ends up in the crapper?
    The chickens of Obama policy are now coming home to roost.

    Poorly-rated. Helpful or Unhelpful: Thumb up 14 Thumb down 49

  8. Tony W says:

    A corporation’s primary duty is to represent the best interests of its shareholders, within the bounds of the law.

    I can remember a day when we pretended other stakeholders mattered too – like the community, the employees and the customers

    Highly-rated. Helpful or Unhelpful: Thumb up 63 Thumb down 6

  9. Raoul says:

    Corporate studies disagree that the shareholders are the best and/or only interests of a company. In exchange for limited liability and enforcing contracts, a company’s interests include good governance and positive employee relations. Antagonizing either it is not in the best “interest” of the company. Basically, people disagree with what is the “best interest” of a company. E.g., can a hundred-million dollar parachute for a failed CEO be in the best interests of a shareholder? And let’s not start with the whole long and short term perspective. In other words, your throwaway line hides a very complex issue.

    Highly-rated. Helpful or Unhelpful: Thumb up 41 Thumb down 2

  10. Scott says:

    Listen, worldwide corporations are now extra national entities that have no boundaries. No nation can create rules and laws that can’t be worked around. Just as within the US where corporations pit state against state and city against city, they are pitting nation against nation. Let’s face it, the drive toward a one world state is coming from these folks, not some politician.

    Personally, I would cancel all corporate taxes, close all loopholes and if that doesn’t work, withhold government services such as courts and military protection. Or charge them piecemeal for those services.

    Like or Dislike: Thumb up 13 Thumb down 1

  11. Tillman says:

    Honestly this seems more like poor business. If the only way to squeeze more profit out of a product is dodge taxes, that speaks very badly of how much growth potential the product has left.

    Highly-rated. Helpful or Unhelpful: Thumb up 33 Thumb down 3

  12. C. Clavin says:

    Many analyses have shown that reforms that lower rates while simultaneously cutting back on loopholes that are based more in political favoritism and crony capitalism than sound tax policy would actually increase tax revenues over time, just as gross tax revenues increased when rates were cut during the Reagan Era.

    Wow…drinking LSD laced Kool-Aid and flashing back to supply-side economics, Doug?
    First..your claim about increased tax revenues due to lower tax rates is very dubious…so you shouldn’t state it as fact. Bush the Greater called it Voodoo Economics. Maybe you remember. Any increase in tax revenues was more likely due to Reagan’s Keynesian policies, and fiscal policies under the Fed which was led by Paul Volcker.
    Second…the reason we can’t get tax reform is that Republicans refuse to accept increased revenues.
    If the party you support would do what you seem to be supporting…then your support would make sense. As it is…not so much.
    Third…Burger King isn’t moving to Canada. (Although I’ve been to Canada recently and I wouldn’t blame them if they did move.) But actually all they are doing is shuffling paper to stiff the US on taxes. So they pay their employees a poverty wage that requires them to seek public assistance to survive…and then they want to avoid the taxes that pay for that public assistance. Serious question; do you support that, Doug? It doesn’t have a sexy name like crony capitalism…but it still sucks.

    What you didn’t say…this is an act of desperation by a dying chain.
    They are getting their a$$ kicked by chains that both serve better food and pay better wages. Faced with that reality the only thing they know how to do is cut expenses…because to do anything else takes creativity and vision. (This is also the reason that the Republican answer for everything is to cut taxes. Because to propose anything else requires thinking…a process anathema to Republicans.)

    Sure…get up on your high-horse and call it demagoguery. And then offer up tired and failed Republican economic theories as a solution.
    Sad.

    Highly-rated. Helpful or Unhelpful: Thumb up 42 Thumb down 10

  13. Scott says:

    @Tony W:

    “A corporation’s primary duty is to represent the best interests of its shareholders, within the bounds of the law.”

    This kind of thinking came into vogue in the 70s and is now treated as if it were an irrefutable truth. It is not.

    Two can play at that game. “The country’s primary duty is to represent the best interests of its citizen’s.” Take that concept to its logical place.

    Highly-rated. Helpful or Unhelpful: Thumb up 47 Thumb down 0

  14. edmondo says:

    If the US government were to tax all US-based sales receipts of foreign-headquartered companies at a higher rate than the corporate income tax, wouldn’t that eliminate the financial incentive to move overseas?

    Like or Dislike: Thumb up 11 Thumb down 0

  15. C. Clavin says:

    @Eric Florack:
    Speaking of tired and failed…there’s Florack…spouting the same crap.
    C’mon…big feller…put your money where your mouth is…walk the walk instead of just talking the talk.
    Tell us what Burger King’s effective tax rate should be. 26 of the biggest corporations in America pay no taxes. Is that low enough?
    Now…you immediately forgo your Social Security and Medicare benefits so that BK doesn’t have to pay taxes. While we are at it ditch your mortgage interest tax deduction and your employer provided health care (subsidized by tax breaks) as well.
    We will wait to see the documentation of these 4 simple steps that verify your commitment to your beliefs.
    Or…if you are unwilling to back up your ideology with action…you should just STFU.

    Highly-rated. Helpful or Unhelpful: Thumb up 21 Thumb down 5

  16. MichaelIsmoe says:

    If the corporations are headquartered in Canada, are they still “people” in the eyes of the Supreme Court? If foreign citizens are prohibited from donating to political campaigns, aren’t foreign based corporations?

    Highly-rated. Helpful or Unhelpful: Thumb up 21 Thumb down 0

  17. Eric Florack says:

    well, lets see. Forbes magazine:

    Canada’s corporate tax rate in Ontario of 26.5% (the federal rate of 15% plus Ontario’s provincial corporate tax rate of 11.5%) is considerably favorable to the American corporate tax rate of 35% thanks in large part to the conservative Canadian government led by Stephen Harper. The Harper government lowered the federal tax rate to 15% in 2012 down originally from 28% since it took office in 2006.

    In fact, a recent KPMG Report, Focus on Tax, ranked Canada as the #1 country with the most business-friendly tax structure among developed countries when adding up a wide range of tax costs to businesses from statutory labor costs to harmonized sales tax. When comparing developed countries to what companies pay in the U.S.; Canada came in at 53.6%, the U.K. came in at 66.6%, and the Netherlands at 74.5% of the U.S. corporate tax burden.

    Canada is recovering at a far faster rate than the US.
    Their economy is booming, because, among other reasons, the leftists running things feel businesses work for them first.

    ITS TIME FOR A CHANGE.

    Poorly-rated. Helpful or Unhelpful: Thumb up 6 Thumb down 31

  18. @edmondo:

    I think the big issue is two fold:

    1. The US treats domestic corporations and foreign ones fundamentally unequally. US corporations based on worldwide revenues, whereas foreign corporations are only taxed on their US operations. As the US becomes responsible for an increasingly smaller share of worldwide GDP, this has become an increasingly bigger competetive disadvantage for US corporations.

    2. We’re using corporate income taxes to make up for problems with our personal income tax system (since it’s politically difficult to raise personal rates, we do that indirectly through corporate taxes), resulting in an unusually high corporate tax rate relative to the rest of the world.

    Like or Dislike: Thumb up 7 Thumb down 0

  19. Eric Florack says:

    @C. Clavin: Lower than 26%.
    for starters.

    Like or Dislike: Thumb up 3 Thumb down 9

  20. al-Ameda says:

    @Eric Florack:

    Canada is recovering at a far faster rate than the US.
    Their economy is booming, because, among other reasons, the leftists running things feel businesses work for them first.

    Plus, they have a single payer health insurance system. Canada is a great country.

    By the way, can you point to an action Obama took to increase the Corporate Tax Rate? I am unaware of any such increase. I realize that you and many conservatives want to blame him for everything, but at least blame him for what he did, not what you claim he did.

    Highly-rated. Helpful or Unhelpful: Thumb up 35 Thumb down 3

  21. anjin-san says:

    @ Florack

    when you tax the lifeblood out of businesses

    Have you taken a look a corporate profits recently? The mountains of cash that so many are sitting on? Compensation that makes C level executives rich beyond the dreams of avarice?

    How is their “lifeblood” being drained? Be specific, no vague right wing bromides please.

    Highly-rated. Helpful or Unhelpful: Thumb up 41 Thumb down 4

  22. Tyrell says:

    @Tillman: That might be right. Our local BK is usually empty. 4-6 people is a crowd for them. I have no idea how they pay their basic expenses: salaries, utilities, and supplies.
    At one time BK had good food. This was true of all the fast food places long ago: regular beef, no additives such as steroids and vitamins, good fries that taste real. Then they started changing. One change for the worse was when they changed the type of oil they use for fries.
    BK needs to get back to basics: a good burger, fries, and a shake at a good price.
    It is hard to believe that Canada would have lower taxes. How things have changed. Something is now backwards.
    This also brings up the subject of franchises. How they work, how to get in, how much to get in, and how they locate. Franchise seminars and conventions usually sell out.

    Like or Dislike: Thumb up 4 Thumb down 0

  23. anjin-san says:

    @ Florack

    Canada is recovering at a far faster rate than the US.

    Lack of multi trillion dollar foreign adventures, tax cuts for billionaires, and endless “defense” spending may have something to do with that, as well as a single payer health care system. I am also willing to bet that they did not have the kind of predatory and fraudulent mortgage schemes we were seeing in this country a decade ago, that probably helped as well. No “war on drugs” perhaps? And I know they don’t have the world’s highest incarceration rate, because we do.

    Canada rocks, no argument here.

    Highly-rated. Helpful or Unhelpful: Thumb up 42 Thumb down 3

  24. C. Clavin says:

    @Eric Florack:
    First: according to Burger King’s annual report their effective tax rate was 27.5% in 2013. Seriously…a 1% point difference. That’s what you are whining about? Holy crap…overthrow the Gubmint. Burger King is failing. They aren’t doing this for taxes. They’re doing it for breakfast.
    Second: Canada is recovering faster because they are NOT pursuing Republican driven austerity…and they are not pursuing Republican driven tax cuts.
    The average Canadian pays about 40% of their income in taxes. The average American pays about 30%….Canadians haven’t seen that since the 60’s…their taxes have been increasing steadily while ours have been decreasing.
    Glad to hear you are advocating for a massive tax increase.

    Highly-rated. Helpful or Unhelpful: Thumb up 20 Thumb down 3

  25. Ben Wolf says:

    @anjin-san: Eric is avoiding that fast food has seen declining revenues in the U.S. This is a result not of corporate tax policies but of deficient and worsening demand in the American market, stemming from mass unemployment and regressive wages championed by men like Steve Forbes. These poor, besieged corporations are doing nothing more than attempting to abscond to another society with wealth they obtained from this one.

    All the Property that is necessary to a man, for the conservation of the individual and the propagation of the species, is his natural right, which none can justly deprive him of: But all property superfluous to such purposes is the property of the publick, who, by their laws, have created it, and who may therefore by other laws dispose of it, whenever the welfare of the publick shall demand such disposition. He that does not like civil society on these terms, let him retire and live among savages

    Highly-rated. Helpful or Unhelpful: Thumb up 29 Thumb down 1

  26. rudderpedals says:

    @MichaelIsmoe:

    If foreign citizens are prohibited from donating to political campaigns, aren’t foreign based corporations?

    Nope, they’re cool. Foreign citizens are probably also OK.

    Like or Dislike: Thumb up 2 Thumb down 0

  27. DA says:

    I don’t know much about the issues, but I would have thought that someone would have mentioned that Burger King is owned by a Brazilian company. I don’t especially see why a Brazilian company has an obligation to base a multinational subsidiary in the US.

    Like or Dislike: Thumb up 2 Thumb down 0

  28. Scott says:

    BTW, Canada had a much smaller recession than the US and it came about 1 year later. The US recession was caused from within while Canada’s economy was hit by collateral damage from the US. The “excessive” (also called conservative) banking regulations prevented the Canadian meltdown.

    Like or Dislike: Thumb up 14 Thumb down 0

  29. Guarneri says:

    Clearly the transaction should be blessed or nixed by Egypt and the UAE. They are obviously running things now.

    Like or Dislike: Thumb up 1 Thumb down 12

  30. James Pearce says:

    Burger King should be condemned for serving crap food.

    Seriously, I’ve been to two different Burger King that have this mural on the wall of young, beautiful, people eating Whoppers off plates. Their fries came in baskets. Their drinks in beautiful glasses with red straws. I’m sitting under this mural and I look at my food, some crushed bun sitting lopsided on a gray piece of meat, and all I could think as I look was, “How come I didn’t go to that Burger King?”

    Because it doesn’t exist, that’s why.

    Like or Dislike: Thumb up 15 Thumb down 1

  31. James Pearce says:

    @Eric Florack:

    the patriotic response would be the elimination of the policies that are damaging businesses.

    The only policy that’s damaging Burger King’s business is their policy of serving crap food.

    Highly-rated. Helpful or Unhelpful: Thumb up 17 Thumb down 1

  32. Guarneri says:

    @DA:

    DA, you poor dear. Repeat after me, in best Neanderthal grunt…….government control and revenue gooooood, lower taxes, baaaaaad. Me squeeze turnip dry……….no jobs. Me no figure out……me blame Republican House.

    Poorly-rated. Helpful or Unhelpful: Thumb up 4 Thumb down 34

  33. Tyrell says:

    @Ben Wolf: “Regressive” wages: that might be true, but there is the factor of competition. if BK is the only show in town for miles around, they could charge $8 for a Whopper in order to pay a burger flipper $12/hour and still have a lot of customers. But if a place moves in across the street and charges $3 for a good burger will put them out of business. I’ll pay the $3
    So this wage argument that we keep hearing is relative to a lot of factors. The local McDonalds has people lined up on their weekly application/interview day. Many of these are students, retired, people looking for part time extra income, and people needing a bridge job until they are re-called. It all comes back to the free market factors of supply and demand: if there are few workers available, the wages have to go up. If they have to raise prices to pay workers more, they risk losing customers and could go out of business. And how does that help? If they raise wages, they will have more educated, experienced, and skilled people applying.I just can’t see paying $15/hour to someone to make a milk shake and drop fries. Compared to some work, at least it is indoors and does not involve heavy lifting. And tthose are pretty good conditions compared to some other jobs, such as working out in 98 degree heat digging ditches or mixing cement.
    It all goes back to the lemonade stand example. Charge too much and lose customers. Charge too little and lose money – go out of business. And there are tons of people who know or can learn how to make lemonade. You pay a little more and you get your choice of the fastest, most dependable, and smartest workers. I generally go for food that is cheap, hot, and fast.

    Like or Dislike: Thumb up 1 Thumb down 15

  34. Guarneri says:

    Get a better job, Pearce. Morton’s Steakhouses are much better……

    Like or Dislike: Thumb up 1 Thumb down 7

  35. PAUL HOOSON says:

    The U.S. needs to do much more to reduce it’s corporate tax rates to spur more economic growth and jobs in this country. One of the most unfair taxes that neither Republicans nor Democrats have ever repealed is the tax on expanding inventory to be paid upfront, and then the same business hit again with taxes when the items actually sell. This is a tax to prevent investment by business, and then a later double tax when the inventory sells. It’s regressive taxes like this that have caused so many American companies to head to places like China.

    Like or Dislike: Thumb up 1 Thumb down 13

  36. James Pearce says:

    @Guarneri: Over at Morton’s, their mural has everyone eating mashed burger-like substances off paper wrappers.

    Like or Dislike: Thumb up 5 Thumb down 0

  37. Guarneri says:

    “Eric is avoiding that fast food has seen declining revenues in the U.S.”

    Ben Smith is avoiding the fact that product demand and prevailing tax rates are completely uncorrelated, but tax rates and return on (easy to go where it wants) capital is inextricably intertwined.

    Like or Dislike: Thumb up 2 Thumb down 8

  38. Guarneri says:

    @James Pearce:

    No, that’s your Uncle Morty’s diner……

    Like or Dislike: Thumb up 2 Thumb down 5

  39. Guarneri says:

    But I have digressed. How the hell do we know how much Burger King pays in taxes? Does the IRS keep its emails these days? Change in Administration?

    Poorly-rated. Helpful or Unhelpful: Thumb up 2 Thumb down 27

  40. Scott says:

    @Tyrell: Are we not better than to treat human beings as just another commodity subject to laws of supply and demand? What then, is the purpose here? The concept you casually throw out there is basically the devaluing of humans with no other reason than to be a human resource to be manipulated by others. This is the opposite of freedom.

    Like or Dislike: Thumb up 11 Thumb down 0

  41. ChefmartyB says:

    @Guarneri: You can look at the 10K of a publicly traded company. I’d refer you to the good folks at Econospeak:

    “But if one takes a look at Burger King’s 10-K, you’ll see that foreign taxes relative to foreign sourced income is around 15%. You’ll also see that about 80% of its income is sourced abroad even though half of its stores are in the U.S. This screams out transfer pricing abuse, which of course Greg Mankiw ignored in his op-ed. Burger King has reported an effective tax rate near 27% precisely because they have been paying the repatriation tax, which is likely why they don’t have a lot of cash abroad. But without the repatriation tax, their effective tax rate would have been less than 20%.”

    Highly-rated. Helpful or Unhelpful: Thumb up 27 Thumb down 0

  42. C. Clavin says:

    @Guarneri:
    Simple. You check their annual report.
    Clearly you have no knowledge of the topic…yet consider yourself knowledgable.
    Shocking.

    Highly-rated. Helpful or Unhelpful: Thumb up 23 Thumb down 1

  43. Tyrell says:

    @Scott: And I agree. When I was a student I worked in the construction field at a wage just a little above minimum wage ( which was not much less than a beginning school teacher here. Hot, heavy, dirty; no easy days. This was unskilled work but I learned some skills and those have really come in handy. I also had great foremen and other guys who taught me the ropes. Tough work, but the owner treated us very well and it turned out to be a valuable experience. The pay is only part of the equation.
    What I am against are these corporate execs who get huge paychecks, huge bonuses while cutting employee pay and cutting jobs.
    BK has been in trouble for years. This move may be a last ditch effort to save the company. I for one would hate to see them go under. It would be bad for a lot of people and communities.

    Like or Dislike: Thumb up 1 Thumb down 0

  44. Matt says:

    @Tyrell: When you were a student working for minimum wage you had a LOT more buying power then you would today working for minimum wage.

    Like or Dislike: Thumb up 9 Thumb down 0

  45. Eric Florack says:

    @James Pearce: well, you and I tend to agree there, but obviously there’s enough folks who disagree with you and I to keep them in business.

    Like or Dislike: Thumb up 1 Thumb down 0

  46. Eric Florack says:

    @Ben Wolf: Ive said nothing about the declining revenue, as a whole, because the fact is that even absent that, theyd still be always on the lookout for a better tax deal.
    But why is their revenue as a segment, declining?
    aha… the economy. Less disposable income.
    and why is the economy troubled?

    Hint: Its not business types.

    Oh, and Rick?
    Say rather, that Canadas economy is booming in spite of single payer, not because of it.

    Poorly-rated. Helpful or Unhelpful: Thumb up 2 Thumb down 24

  47. bill says:

    @wr: is that a steve jobs quote, or was that bill gates? funny how those who squawk the loudest about this kind of crap usually do it from an iphone – and they have no idea how ironic it is, that’s the scary part.
    then again i never read a headline that said “federal gov’t. outsmarts big business”.

    Like or Dislike: Thumb up 1 Thumb down 8

  48. Tony W says:

    @Eric Florack:

    Less disposable income.
    and why is the economy troubled?

    I’m happy to hear that you are finally in favor of policies to assist the working class so that they have income to spend in those business you cherish so much. We’ll tax the rich and lower the burden on those used to have disposable income before St. Ronnie led us into this mess.

    Highly-rated. Helpful or Unhelpful: Thumb up 22 Thumb down 0

  49. C. Clavin says:

    @Eric Florack:

    theyd still be always on the lookout for a better tax deal.

    That 1% tax break???
    Why do you choose to ignore every single fact that flies in the face of your ideology…and every question that can’t be answered in a manner consistent with your beliefs?
    Like all bigots… You’re simply a deluded fool.

    Highly-rated. Helpful or Unhelpful: Thumb up 18 Thumb down 1

  50. anjin-san says:

    @ Florack

    Say rather, that Canadas economy is booming in spite of single payer, not because of it.

    Can you support that statement with an economic argument that makes sense and contains specifics?

    Highly-rated. Helpful or Unhelpful: Thumb up 20 Thumb down 1

  51. anjin-san says:

    @ Florack

    why is the economy troubled?

    You ran away yesterday, so I ask again. Do you own anything? Stocks, or real estate for example. If the answer is yes, are your investments doing better than they were the day before Obama took office?

    Like or Dislike: Thumb up 15 Thumb down 1

  52. wr says:

    @bill: English, please.

    Like or Dislike: Thumb up 7 Thumb down 1

  53. anjin-san says:

    @ Florack

    Less disposable income.

    Hey rocket scientist. Less disposable income is good for fast foot joints. People skip Chili’s and Applebee’s & go to Burger King and Taco Bell.

    The Burger King near us is mostly empty, as it the McDonalds. In & Out Burger, on the other hand, is so busy it’s difficult to even get into the shopping center it is in. Why? Better food & better paid people serving it.

    Highly-rated. Helpful or Unhelpful: Thumb up 22 Thumb down 2

  54. Just 'nutha' ig'rant cracker says:

    @Eric Florack: We’re taxing our businesses to death? Really? I mean, I like hyperbole as much as the next guy, but come on, companies that have a total of $2 trillion to stash in foreign countries are not being taxed to death.

    Highly-rated. Helpful or Unhelpful: Thumb up 31 Thumb down 1

  55. Just 'nutha' ig'rant cracker says:

    @Ben Wolf: Your quote is from “our hero” Adam Smith, is it not?

    Who knew that he was a closet redistributionist?

    Like or Dislike: Thumb up 6 Thumb down 0

  56. Todd says:

    Not being an economist, I’m not sure how/if this would even work, but I’ve often thought that a novel idea would be to just totally eliminate corporate taxes … But Then, also eliminate the special tax rates for dividends and capital gains. Income is income, and is always taxed at the individual rate, regardless of its source. lol, such a plan could never be enacted though, as I’m sure the howls of derision would pale in comparison to anybody’s problems with the current corporate tax code. :-)

    Like or Dislike: Thumb up 12 Thumb down 0

  57. Eric Florack says:

    @Tony W: want to “assist the working class”?
    Get government out of the way. Letting business do its thing without governmental micromanagement and over taxation is the best thing you can do to help the working class.

    @Todd: That’s an idea that will solve many issue. What, after all, are taxes on businesses, but a hidden tax, which is passed on to and paid by “the working class”, in the form of higher prices? When the tax burden gets shifted to voters and they see clearly how much of our money is being taken to support Democrat utopia, what do you suppose happens to the left, hmmm?

    Poorly-rated. Helpful or Unhelpful: Thumb up 0 Thumb down 30

  58. Stan says:

    If every American corporation incorporated in another country to lower its taxes the US government would have to make up for the loss of income by either increasing income taxes or decreasing spending. The effect on our economy and on our collective well-being would be profound. I don’t know how it would play out, and I don’t think anybody does. So before applauding Burger King for following Milton Friedman’s First Law of Acquisition, i. e. sauve qui peut, think about the consequences if every corporation followed Burger King’s lead.

    Like or Dislike: Thumb up 3 Thumb down 1

  59. Tyrell says:

    @anjin-san: We have three fast food joints, counting one BK. One does a packed breakfast every morning. All three do ok at lunch. None do well in the evening. At 6:00 this town has rolled up the sidewalks and is shut down.
    I don’t choose a restaurant based on how much the employees get paid. I don’t know how much they get paid. Good pay could result in better service, and food.
    I do have many fond memories of Burger King. Nice, friendly atmosphere. Family oriented.

    Like or Dislike: Thumb up 0 Thumb down 1

  60. SC_Birdflyte says:

    @Tony W: One change in our tax laws I would like to see is to make capital gains on shares granted to executives via stock options taxable as ordinary income, not as capital gains. As a direct shareholder of over thirty companies, my shares were acquired with after-tax dollars, not handed to me as compensation.

    Like or Dislike: Thumb up 9 Thumb down 0

  61. JWH says:

    Eh?

    Like or Dislike: Thumb up 0 Thumb down 0

  62. C. Clavin says:

    @Eric Florack:

    over taxation

    Again…a 1% difference is over-taxation?
    Every single claim you make is completely unsupported by fact.
    Do you ever think to yourself ; maybe that’s a problem?

    Like or Dislike: Thumb up 8 Thumb down 2

  63. C. Clavin says:

    @Eric Florack:

    they see clearly how much of our money is being taken to support Democrat utopia

    Burger King pays poverty wages …and forces it’s employees to depend on government benefits to survive. They don’t, however , want to pay taxes to support those benefits .
    That’s not Democratic utopia . That’s Corporate welfare… Republican utopia.
    You don’t even know what you are arguing about.

    Highly-rated. Helpful or Unhelpful: Thumb up 23 Thumb down 2

  64. jukeboxgrad says:

    Tony W:

    I can remember a day when we pretended other stakeholders mattered too

    According to current conservative dogma, government is the problem. If we make government small, this will enable the ‘free market’ to rise up and generate prosperity, lifting us all.

    This fable is deceptive because it fails to take certain major problems into account. Here’s one key problem it ignores: business used to be patriotic, but it isn’t anymore. And here’s another key problem it ignores: a society with a strong middle class is not the natural state of mankind. These two problems are closely related.

    To understand the first problem, read National Review, and you will learn that CEOs used to care about more than just maximizing profits: link. That important and overlooked article talks about “the robust public-spiritedness and patriotism that helped define corporate America in the mid 20th century,” and how maybe it would be a good idea “for corporate America to recover its former patriotism.”

    And this is related to something else you can read at National Review:

    I have been using the term “corporate America,” but this moniker is something of a misnomer in an age when executives are increasingly “post-American” and major businesses almost always identify themselves as global ventures. Not untypical are comments from the vice president of Coca-Cola, who said in a speech in 2005, “We are not an American company,” and from a top Colgate-Palmolive executive, who in 1989 said, “There is no mindset [at Colgate] that puts this country [the United States] first.”

    Speaking to Atlantic reporter Chrystia Freeland in 2011, a U.S.-based CEO of one of the world’s largest hedge funds described an internal debate at his company. One of his senior colleagues had suggested that the “hollowing out of the American middle class didn’t really matter,” the CEO told Freeland, adding: “His point was that if the transformation of the world economy lifts four people in China and India out of poverty and into the middle class, and [that] meanwhile means one American drops out of the middle class, that’s not such a bad trade.” Almost a decade ago, Samuel Huntington identified this trend as the “de-nationalization” of American corporate elites. The new “economic transnationals,” he said, are the “nucleus of an emerging global superclass.”

    The destruction of the middle class and the rise of extreme income inequality are essentially two different names for the same phenomenon. The many conservatives who say ‘inequality does not matter’ (which happens to be the exact title of an article by Kevin Williamson) are essentially defending the executive who said the “hollowing out of the American middle class didn’t really matter.”

    And this process of destroying the middle class, which has been underway for about thirty years and which is accelerating, is simply a reversion to the natural state. The natural state of humankind is a two-class society, where there are rich and poor, and no one in between. That is what most human societies have looked like, through history.

    A middle class does not arise spontaneously. It needs to be created deliberately, via government policies (which is why people like Adam Smith and Thomas Jefferson advocated progressive taxation). And there is no democracy without a middle class, which is why Greenspan said what he said (that extreme income inequality “is not the type of thing which a democratic society—a capitalist democratic society—can really accept without addressing”).

    The GOP call for ‘small government’ is an effort to undo the government policies that gave us the strong middle class we used to have. Thirty years of Reaganism have returned us to the Gilded Age. The difference is that now we have globalization, which means that this time the Gilded Ones are a “global superclass” with no national identity or loyalty. The American middle class is an inconvenience to them, and they will continue to crush it. Government is also an inconvenience to them, because government is the only force powerful enough to constrain them. It’s true that they buy government and then take advantage of government power, but they prefer government to be powerless.

    By the way, Republicans used to understand this. Remember that great Marxist Teddy Roosevelt? He is known for “arguing that the rise of industrial capitalism had rendered limited government obsolete.” And it was the greatest Republican of all who said this, in 1837:

    These capitalists generally act harmoniously, and in concert, to fleece the people

    If you are outside the 99% and calling for ‘small government’ you are cutting your own throat.

    My apologies to those who already saw this when we discussed this subject in March.

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  65. Tyrell says:

    @C. Clavin: It would be a big loss to our town if the Burger King ever closed. Loss of jobs, and loss of the town’s top social gathering place. And loss of a place where a family can enjoy good food without going broke. Lots of nice memories there.

    Like or Dislike: Thumb up 0 Thumb down 0

  66. anjin-san says:

    Letting business do its thing

    Which in the year 2014 is often letting business f**k anybody and everybody in search of maximized profits so that a handful of people can make more money than they could spend in several lifetimes.

    Did you hear about T Mobile “overcharging” it’s customers hundreds of millions of dollars? Guess they were just “doing their thing”…

    Like or Dislike: Thumb up 12 Thumb down 2

  67. jukeboxgrad says:

    wr:

    Remember, kids, the only thing that matters in life is that you amass as much money as humanly possible

    The core of Republicanism is the worship of money and the people who have it. That’s why Republicanism elevates capitalism and shows contempt for democracy (link).

    The ideal Republican society is China, where capitalism thrives in the absence of democracy. Making the US look more like China is a key goal of Republicanism.

    Like or Dislike: Thumb up 14 Thumb down 2

  68. Mikey says:

    Lots of moral outrage here for a company exploring an option that allows it to do something we all do, which is not pay any more in tax than we’re legally obligated to pay.

    I mean, I’m pretty sure nobody gets to the “tax due” line of their 1040 every April and says “Wow, that number just isn’t big enough. I’m going to tack on an extra couple hundred bucks.” Nobody calls their accountant and says “Make sure I pay at least 10% more in tax than I’m legally required to pay.” (Or maybe you do, in which case…well, it’s your money. Or was.)

    Doug is right when he writes

    the rational thing would be to look at our corporate tax laws and determine how we can change them to discourage this type of behavior

    If you want to change this behavior by corporations, you have to change the law. Make it cost more to make these moves than the company saves in tax payments. Simplify the tax code so it’s no longer worth paying consultants an assload of money to find the loopholes.

    Yelling “meanie meanie poopie heads!” at Burger King, or other corporations that have struck similar deals with foreign companies, isn’t accomplishing anything.

    Like or Dislike: Thumb up 3 Thumb down 9

  69. Tony W says:

    Lots of moral outrage here for a company exploring an option that allows it to do something we all do, which is not pay any more in tax than we’re legally obligated to pay.

    Not precisely. I live in California but own homes in other states that happen to be “no income tax” states. I divide my time well enough between homes that I could probably pull a Leona Helmsley and register one of those states as my home state and avoid state income tax altogether. I don’t do it because that would be unethical. I am dependent upon the services that California provides me, and it’s only fair that I pay for them.

    Because ethics are more important to me than money, I’ll never be one of the uber rich. That’s okay.

    Highly-rated. Helpful or Unhelpful: Thumb up 24 Thumb down 0

  70. C. Clavin says:

    @Mikey:

    If you want to change this behavior by corporations, you have to change the law. Make it cost more to make these moves than the company saves in tax payments. Simplify the tax code so it’s no longer worth paying consultants an assload of money to find the loopholes.

    Sure…let me know just as soon as Republicans are willing to work on this.

    Like or Dislike: Thumb up 13 Thumb down 1

  71. Mikey says:

    @Tony W: It’s not ethical in your view, but it might be in someone else’s. They might consider it more ethically sound to pay less tax and spend the money on their kids’ education or something like that.

    The point is, the company is acting entirely rationally, and the way to change its actions is to change the law so different actions are rational.

    Like or Dislike: Thumb up 1 Thumb down 12

  72. C. Clavin says:

    Moderator….
    Please release me, set me free…..

    Like or Dislike: Thumb up 1 Thumb down 1

  73. Barry says:

    Doug: “All of these responses, and more like them, are tinged more with moral resentment than any rational considerations of public policy. If companies like Burger King are considering inversion deals to save money, and others are parking trillions in cash overseas for the same reason, then the rational thing would be to look at our corporate tax laws and determine how we can change them to discourage this type of behavior. ”

    Corporations will always seek lower taxes, no matter what. That has no implication whether or not we should change – meaning lower – their taxes.

    Like or Dislike: Thumb up 6 Thumb down 1

  74. KM says:

    Drinking a Timmy Ho’s Frozen Chocolate as I type this so I might be a bit biased. Go Timmy’s!!

    Burger King (like most companies) goes out of its way to integrate itself with your life to the point where advertisements regularly hit topics like patriotism, family values, etc in an attempt to get you associate them with your preferred conception of your life. The term is brand loyalty – they want you to be loyal to them so they do everything in their power to make you possessive of them, make you think of them as “yours”. So when Burger King just causally goes “see ya, moving to Canada”, people are not going to be pleased. It’s going to feel like irrational abandonment specifically because that’s how they trained us to think. The optics on this are poor enough as it is without tossing in several million Americans who now have a subconscious kneejerk objection to their company leaving them- add in most Americans have a lukewarm appreciation of Canada at best, BK blatantly saying they’re doing it just for the money and you get this mess. They look like money-grubbing jerks and they have no one to blame but themselves.

    Like or Dislike: Thumb up 11 Thumb down 0

  75. Scott says:

    Burger King (like most companies) goes out of its way to integrate itself with your life to the point where advertisements regularly hit topics like patriotism, family values, etc in an attempt to get you associate them with your preferred conception of your life.

    Here is a thought for discussion: If US corporations are following rational behavior without regards to national boundaries and pride, does this have a pernicious effect on American citizens and their patriotic viewpoint towards the country. Phrased another way, are US corporations undermining the American citizens natural patriotism, loyalty, and pride.

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  76. Guarneri says:

    Well, well, well. Liberal convenient fave Warren “I really should pay more taxes” Buffet to help finance Boigga King purchase of Hortons. And the band played on…….

    Poorly-rated. Helpful or Unhelpful: Thumb up 2 Thumb down 17

  77. C. Clavin says:

    To the point of tax reform…yes, definitely.
    1 – Loopholes, special deductions, capital gains…save people (mostly the 1%) That’s a revenue loss of $1.25 trillion a year. Enough to completely fund SS and Medicare.
    2 – Corporate Taxes: The average effective tax rate for American Corporations from ’87 to ’08 was 22.5%, an extremely low rate worldwide. Since the Bush Contraction that rate has dropped to 10% while profits have skyrocketed. The difference amounts to a $250B revenue loss.
    3 – Tax Havens account for $250B a year in revenue loss.
    4 – Underpayment of taxes accounts for $450B a year in revenue loss.
    So yeah…we should do tax reform. Make it simpler. Make it fairer.
    The problem…as with almost everything today…is Republicans. They want to codify all these revenue losses…and eliminate Social Security and Medicare and a host of other programs in order to pay for them. They aren’t interested in fair. They are interested in protecting the income of the 1% at the expense of the nation as a whole.

    Like or Dislike: Thumb up 13 Thumb down 1

  78. Guarneri says:

    @Scott:

    No. And in other news, Scott has graduated from 6th grade. His parents are proud.

    Poorly-rated. Helpful or Unhelpful: Thumb up 2 Thumb down 18

  79. Guarneri says:

    @C. Clavin:

    Care to comment on the incidence of corporate taxes? Those pieces of paper in Delaware pay none.

    Poorly-rated. Helpful or Unhelpful: Thumb up 2 Thumb down 18

  80. Rafer Janders says:

    @Eric Florack:

    want to “assist the working class”? Get government out of the way. Letting business do its thing without governmental micromanagement and over taxation is the best thing you can do to help the working class.

    Which is why Somalia has such a thriving working class.

    Highly-rated. Helpful or Unhelpful: Thumb up 26 Thumb down 3

  81. C. Clavin says:

    @Guarneri:
    26 of Americas largest corporations paid no tax between ’08 and ’12…Boeing, General Electric, and Verizon among them. Yet Republicans keep telling us that our tax burden is debilitating.
    Sowhat’s your point?

    Highly-rated. Helpful or Unhelpful: Thumb up 17 Thumb down 1

  82. al-Ameda says:

    @Eric Florack:

    Oh, and Rick?
    Say rather, that Canadas economy is booming in spite of single payer, not because of it.

    You can’t have it both ways – Canada has higher marginal tax rates, single-payer health insurance AND their economy is doing very well. I would say that because Canadian businesses do not have to provide health insurance benefits they can instead provide their employees with other benefits and increased compensation.

    Highly-rated. Helpful or Unhelpful: Thumb up 15 Thumb down 0

  83. C. Clavin says:

    @al-Ameda:

    You can’t have it both ways

    If he can’t have it both ways…he has nothing to say.

    Like or Dislike: Thumb up 10 Thumb down 2

  84. Tyrell says:

    @KM: In our area, BK has been around for a while. So it is a trusted brand to people here. More than that, it is a nice place to hang out and socialize: clean, friendly, play area, good prices, good food, good service, courteous employees. Hard to find a place like that, especially around here. So this “integrate” thing can work the other ways. For many people BK might just be an important place in their lives and fulfills some sort of purpose.That does not mean it is packed most of the time.

    Like or Dislike: Thumb up 3 Thumb down 0

  85. Guarneri says:

    @C. Clavin:

    My point is that you probably didn’t even understand, much less have any insight as to the question posed, relevant as it is to the topic – disqualifying you from being taken seriously in any debate on the topic except by your fellow know-nothings. But looking at the bright side, as per a recent essay at OTB, at least your selfies are yours.

    Poorly-rated. Helpful or Unhelpful: Thumb up 1 Thumb down 17

  86. C. Clavin says:

    @Guarneri:
    blah blah blah…just more nonsense.
    you asked a vague question….lacking any context for judgement…on a topic to which the opinions of experts in the field (and you are clearly not an expert) differ wildly.
    get back to me when you have something a little less incoherent to discuss.

    Like or Dislike: Thumb up 6 Thumb down 2

  87. jukeboxgrad says:

    Florack:

    What, after all, are taxes on businesses, but a hidden tax, which is passed on to and paid by “the working class”, in the form of higher prices?

    This is an example of conservative nonsense that is repeated incessantly.

    Taxes are a cost. Higher costs do not necessarily cause higher prices. They can cause higher prices, lower profits, or both.

    If in the event of a tax increase you were always able to simply ‘pass the costs on’ (as you are implying), that means your prices were too low and you would have already raised them to what the market can bear.

    So thanks for proving, again, that you don’t know what you’re talking about.

    Like or Dislike: Thumb up 12 Thumb down 1

  88. Eric Florack says:

    @C. Clavin: I said ‘for starters’.
    Ponder the idea that it took Obama to make companies move to Canada.

    Like or Dislike: Thumb up 0 Thumb down 14

  89. jukeboxgrad says:

    Guarneri:

    disqualifying you from being taken seriously in any debate on the topic except by your fellow know-nothings

    You said this:

    How the hell do we know how much Burger King pays in taxes?

    An incredibly stupid statement. So the irony is priceless.

    Highly-rated. Helpful or Unhelpful: Thumb up 17 Thumb down 1

  90. al-Ameda says:

    @Eric Florack:

    Ponder the idea that it took Obama to make companies move to Canada.

    Ponder the idea that you’re saying that Burger King left the country because Barack Obama (who has not raised federal corporate tax rates) is our president.

    Highly-rated. Helpful or Unhelpful: Thumb up 24 Thumb down 1

  91. jukeboxgrad says:

    Ponder the idea that it took Obama to make companies move to Canada.

    Ponder the ignorance of someone who thinks corporate inversions were invented on 1/20/09. But all good conservatives think history began on that date.

    Highly-rated. Helpful or Unhelpful: Thumb up 16 Thumb down 1

  92. Eric Florack says:

    @C. Clavin: Clavin, every time we get liberals in power, the economy hits the crapper.
    Every.
    Single.
    Time.
    That’s called “cause and effect”.
    Do you really think we didn’t notice the trend?
    @al-Ameda:
    In the end, its policy that makes the difference.
    Now, unless you are prepared to argue that Jimmy Carter was actually the first black president…..

    Poorly-rated. Helpful or Unhelpful: Thumb up 1 Thumb down 19

  93. reid says:

    @Eric Florack:

    every time we get liberals in power, the economy hits the crapper.

    This is 100% completely false. Not only that, it’s obviously false to anyone who was alive the last ten years. What is wrong with you?

    Highly-rated. Helpful or Unhelpful: Thumb up 29 Thumb down 1

  94. Eric Florack says:

    Peter Morci puts it this way…

    Simply, the U.S. federal corporate tax rate is 35 percent and applies to both Burger King’s domestic and overseas profits, whereas Canada’s rate is 15 percent and only applies to Tim Horton’s domestic sales.

    In the second quarter of this year, Burger King’s federal and state income taxes were 24 percent of its operating costs and 34 percent of its profits. Locating in Canada would cut those figures by up to 25 percent.

    No responsible CEO or corporate board could reasonably ignore those figures, and that’s why about 60 U.S. companies have completed or plan so called “tax inversions”—acquisitions or mergers with foreign companies that permit them to locate their tax address in a friendlier jurisdiction.

    What American businesses actually pay in federal and state income taxes varies a lot, thanks to many exemptions, deductions and provisions to delay taxes on foreign earnings; however, the average combined U.S. and foreign tax burden on profits is about 30 percent, whereas the average for foreign rivals is about 23 percent.

    Like or Dislike: Thumb up 1 Thumb down 8

  95. anjin-san says:

    @ Florack

    Still ducking my question about how your investments have done since Obama took office, I see.

    What are you running from? The truth?

    Like or Dislike: Thumb up 6 Thumb down 1

  96. C. Clavin says:

    @Eric Florack:
    Peter Morci is ignoring the Provincial taxes…and overstates BK’s tax burden.
    Of course you would quote someone who is wrong. You are always wrong.
    Canada’s corporate tax rate in Ontario is 26.5% (the federal rate of 15% plus Ontario’s provincial corporate tax rate of 11.5%)
    According to BK’s annual corporate report they payed an effective tax rate of 27.5% last year.
    That’s 1%. BFD.
    They are doing this because they are dying…and they want the breakfast business to compete with Dunkin and others.
    Buy a dog…name it Clue…then you will have one.

    Like or Dislike: Thumb up 12 Thumb down 1

  97. anjin-san says:

    @ Florack

    Democrat utopia

    You mean the utopia where we don’t have people starving to death in our country, dead bodies in the street, and the have nots randomly killing the haves because they have moved from desperation to blind rage?

    I guess in tea party America, that’s a luxury we can’t afford. Because billionaires need tax cuts.

    Like or Dislike: Thumb up 8 Thumb down 1

  98. C. Clavin says:

    @Eric Florack: @Eric Florack:

    Clavin, every time we get liberals in power, the economy hits the crapper.

    You fvcking idiot. The Dow when Bush left office was 8000. Today it is 17,000.
    Maybe that word…crapper…doesn’t mean what you think it means.
    http://www.princeton.edu/~mwatson/papers/Presidents_Blinder_Watson_Nov2013.pdf

    Like or Dislike: Thumb up 10 Thumb down 1

  99. al-Ameda says:

    @Eric Florack:

    @al-Ameda:
    In the end, its policy that makes the difference.
    Now, unless you are prepared to argue that Jimmy Carter was actually the first black president…..

    So actual increases in the tax rates don’t matter? Interesting.
    Again, did Obama increase the federal corporate tax rates?

    Like or Dislike: Thumb up 7 Thumb down 0

  100. al-Ameda says:

    @Eric Florack:

    Clavin, every time we get liberals in power, the economy hits the crapper.
    Every.
    Single.
    Time.
    That’s called “cause and effect”.
    Do you really think we didn’t notice the trend?

    Actually, I’ve noticed that the two single-most catastrophic economic collapses in modern American history – The Great Depression of 1929-1940 and the Great Recession of 2008-2009 happened when a Republican president was on the watch.

    That’s called “facts.”

    Like or Dislike: Thumb up 14 Thumb down 1

  101. JWH says:

    @C. Clavin:

    Eh?

    Like or Dislike: Thumb up 0 Thumb down 0

  102. michael reynolds says:

    @Guarneri:

    Well, as a financial advisor to Jimmy John’s, Drew, we know your pathway to profit, don’t we: steal from employees. Drew’s lessons in capitalism: 1) Steal from employees, 2) Steal from society at large. 3) Blame liberals.

    Like or Dislike: Thumb up 11 Thumb down 0

  103. michael reynolds says:

    Doug:

    The moral vacuity of your philosophy is what keeps libertarianism from growing. Most people over the age of, say, 25, manage to develop a moral core. Which is why libertarianism in the young is merely embarrassing, while libertarianism in adults is disturbing.

    Highly-rated. Helpful or Unhelpful: Thumb up 21 Thumb down 0

  104. C. Clavin says:

    @michael reynolds:
    Wait…Guarneri is Drew???
    The worlds greatest business-person???
    That explains so freakin’ much.

    Like or Dislike: Thumb up 7 Thumb down 0

  105. michael reynolds says:

    @C. Clavin:

    Yep. The same Drew who has yet to manage to support a single point, or to really refute anyone else’s point, but pops up from time to time to disgorge random bits of scorn and harrumphing. Master of the Universe.

    Like or Dislike: Thumb up 13 Thumb down 0

  106. Eric Florack says:

    @C. Clavin: You really think the dow is connected to any facit of reality?

    @al-Ameda: No, thats called incomplete information.

    @michael reynolds: This from somone whose politcs is based on the confiscation of other people’s money and how to divide up the stolen loot. Im supposed to be impressed?

    @anjin-san: You mean theres dead people on the streets in Canada? Youd think wed be seeing more about that.

    @C. Clavin:I call BS. If theyre dying why are you so upset? They would bring in much tax revenue anyway, right?

    Like or Dislike: Thumb up 0 Thumb down 11

  107. Eric Florack says:

    Oh… and any of you guys ever heard of Delphi?

    Like or Dislike: Thumb up 0 Thumb down 3

  108. Hal_10000 says:

    1. The US treats domestic corporations and foreign ones fundamentally unequally. US corporations based on worldwide revenues, whereas foreign corporations are only taxed on their US operations. As the US becomes responsible for an increasingly smaller share of worldwide GDP, this has become an increasingly bigger competetive disadvantage for US corporations.

    The US one of the few countries that does this. If you base your operations in Canada, you pay tax on Canada sales to Canada, US sales to the US, UK sales to the UK. If you base your corporation in the US, you pay taxes on Canada sales to Canada, UK sales to the UK — and the taxes on *all* sales to the US (w/ some credit for taxes paid in other countries). Most countries are smart enough not to punish corporations that are bringing in money from overseas like that or put them at such a competitive disadvantage in foreign markets. This is why companies have $2 trillion in un-patriated profits. If you want to fix this, end the taxation on overseas earnings, the way every other functional country does. Go with territorial taxation. Instead, we’ve moved in the other direction.

    As for the allegation that this makes Burger King a bad corporate citizen … if they move to Canada, that will not affect what they pay their American employees or how many American employees they have (since almost all their domestic operations will remain here). I understand the idea of corporations having larger responsibilities than profits but deliberately maximizing their tax bill isn’t one of them.

    Like or Dislike: Thumb up 0 Thumb down 2

  109. C. Clavin says:

    @Eric Florack:
    Yeah…that’s the center of Zeus’s world…where the navel of Gaia is located.

    Like or Dislike: Thumb up 5 Thumb down 0

  110. C. Clavin says:

    @Hal_10000:

    This is why companies have $2 trillion in un-patriated profits.

    Right…and that’s why BK’s tax rate is 27.5%. Were it not for that their rate would be something south of 20%. Everyone crying about taxes is delusional.

    Like or Dislike: Thumb up 3 Thumb down 0

  111. sam says:

    @Eric Florack:

    every time we get liberals in power, the economy hits the crapper.
    Every.
    Single.
    Time.

    History Shows Stocks, GDP Outperform Under Democrats:

    According to McGraw-Hill’s (MHP) S&P Capital IQ, the S&P 500 has rallied an average of 12.1% per year since 1901 when Democrats occupy the White House, compared with just 5.1% for the GOP.

    Likewise, gross domestic product has increased 4.2% each year since 1949 when Democrats run the executive branch, versus 2.6% under Republicans.

    Even corporate profits show a disparity: S&P 500 GAAP earnings per share climbed a median of 10.5% per year since 1936 during Democratic administrations, besting an 8.9% median advance under Republicans, S&P said.

    That’s from Fox News, no less. Bithead, still wrong

    Every.

    Single.

    Time.

    Highly-rated. Helpful or Unhelpful: Thumb up 26 Thumb down 0

  112. Eric Florack says:

    @C. Clavin: You may want to do some research on the topic in this context, and considerably more recent.
    Then again, given what it does to your argument you may want to remain intentionally ignorant. Its your strongest suit.

    Poorly-rated. Helpful or Unhelpful: Thumb up 0 Thumb down 16

  113. C. Clavin says:

    @Eric Florack:
    You haven’t made a single statement that was based in fact as long as I’ve been seeing your comments. Just today you have made several statements that are demonstrably untrue.
    On top of that you are an unrepentant bigot.
    Why would I bother? Seriously?

    Like or Dislike: Thumb up 12 Thumb down 0

  114. MR X says:

    Whats with all the big fuss over this?

    It’s big companies using very expensive M&A lawyers to exploit loopholes. There’s nothing new here. Oh, I forgot its an election year so we’ll be hearing people chirp about this until November.
    then it will disappear for two years while the biggest companies contribute to both parties to keep the status quo.

    http://online.wsj.com/articles/how-tax-inversions-became-the-hottest-trend-in-m-a-1407240175

    Like or Dislike: Thumb up 8 Thumb down 0

  115. jukeboxgrad says:

    C. Clavin:

    The Dow when Bush left office was 8000. Today it is 17,000.

    The Dow dropped 22% during Bush’s term (after more than tripling during Clinton’s). If the Dow is higher than 6475 on the day Obama leaves office (a 62% drop from where it is now), then he will have done better than GWB, on this metric.

    Unemployment rate is another important number. Unemployment rate when Bush took office: 4.1%. Unemployment rate when Bush left office: 7.8%. Those tax cuts really worked.

    Like or Dislike: Thumb up 15 Thumb down 1

  116. Eric Florack says:

    @C. Clavin: well, try this.
    what about businesses leaving California for Texas?

    Like or Dislike: Thumb up 1 Thumb down 9

  117. C. Clavin says:

    Everytime I reply to jukebox I get trapped in the spam filter.

    Anyway…for Obama to perform as badly at job creation as Bush UE would have to be at 14.8% when he leaves office.
    Anyone care to wager? Florack is willing to bet his monthly Social Security check.

    Like or Dislike: Thumb up 4 Thumb down 1

  118. al-Ameda says:

    @Eric Florack:

    @al-Ameda: No, thats called incomplete information.

    Unfortunately for you it’s called “reality-based, accurate information”

    Like or Dislike: Thumb up 8 Thumb down 1

  119. C. Clavin says:

    @Eric Florack:
    Race to the bottom, Bigot-Boy. Race to the bottom.

    Like or Dislike: Thumb up 3 Thumb down 1

  120. steve q says:

    One of the reasons Canada’s doing much better than us is that their banks were much more tightly regulated than ours. So while our banks did the inevitable risky shit, and crashed the system, and froze the lending markets, and had to be bailed out, Canada had no such crisis.

    In fact if you look at the big deregulation events, (20’s stock market, 80’s airlines and Savings-and-Loans, late 90’s derivatives,…) they’ve basically all resulted in crises.

    Highly-rated. Helpful or Unhelpful: Thumb up 16 Thumb down 0

  121. michael reynolds says:

    @Eric Florack:

    What you call “confiscation” of private property is what everyone else calls “civilization.”

    Please show me a single society in all of recorded human history that did not impose taxation. Just one.

    Show me a single modern, developed nation that does not tax to support a social safety net.

    In the sure knowledge that you will have zip, let me point out that taxation is required for all those lovely bombs you forever want to drop on people. So unless you think military forces come magically along, riding on unicorns, you’ve already accepted taxation in principle.

    Your actual objection is not to taxation, but to expenditures on people you don’t like. Try again, Eric.

    Highly-rated. Helpful or Unhelpful: Thumb up 20 Thumb down 1

  122. michael reynolds says:

    @MR X:

    No, it’s companies exploiting the tax-supported stability, and the tax-supported infrastructure that allowed them to grow, and then, when they get the chance, telling everyone who contributed to their success to drop dead.

    I grant you that’s normal enough for, say, a teen-aged boy. But kinda disgusting coming from an adult.

    This is a problem easily dealt with: pass a law that tax fugitive corporations and their subsidiaries cannot sign any contract with the US government. That would include the BK’s on military facilities. They’re free to leave, but we don’t have to give them any more taxpayer money. What with them hating taxation and all.

    Like or Dislike: Thumb up 12 Thumb down 1

  123. jukeboxgrad says:

    C. Clavin:

    Everytime I reply to jukebox I get trapped in the spam filter.

    That’s because you tried to use the Reply feature. It works, except if you are replying to me. Don’t ask why. It’s classified.

    Like or Dislike: Thumb up 3 Thumb down 0

  124. anjin-san says:

    One of the reasons Canada’s doing much better than us is that their banks were much more tightly regulated than ours.

    Ironically, Texas avoided much of the carnage of the real estate collapse because of a highly regulated banking environment.

    Like or Dislike: Thumb up 11 Thumb down 0

  125. Jenos Idanian #13 says:

    BK should do whatever the hell it thinks is in its best interest. The people who are most upset at BK for considering this move already hate them already.

    They hate them for 1) being a huge company, 2) not paying absurdly high wages for very undemanding work, 3) serving mediocre food, and 4) offering cheap food to poor people. I don’t think it’s possible for the professional left to hate them more. And even if they do, what are they gonna do about it?

    Poorly-rated. Helpful or Unhelpful: Thumb up 1 Thumb down 17

  126. Pinky says:

    @KM: Don’t you think that most people go to Burger King for the food?

    Like or Dislike: Thumb up 2 Thumb down 0

  127. al-Ameda says:

    @Jenos Idanian #13:

    I don’t think it’s possible for the professional left to hate them more. And even if they do, what are they gonna do about it?

    “The professional left” as compared to the “professional right,” who prefers food to be comprised of unidentified animal parts served between a convincing bread substitute? Oh, I don’t know, maybe we’ll purchase ‘real’ food.

    Like or Dislike: Thumb up 7 Thumb down 1

  128. Pinky says:

    @jukeboxgrad: There must be some combination of letters in your handle that trigger the filter. Have you tried just putting in spaces or a hyphen?

    Like or Dislike: Thumb up 1 Thumb down 0

  129. Pinky says:

    @Pinky: Second question, why did that last comment get through without a problem?

    Like or Dislike: Thumb up 2 Thumb down 0

  130. anjin-san says:

    @ Jenos

    very undemanding work

    Have you ever worked in the food service industry? It’s actually pretty demanding and very stressful. When you consider that a fast food worker has zero power to change their work environment for the better or resolve disputes with customers, management, or corporate, they are getting pressure from several directions at once to go along with the poverty wages.

    I was at In & Out Burger the other day. Their were roughly 30 cars in the drive-thru line, and a double line going out the door at the registers. The workers were going balls to the wall. At this location, a rush like that can go on for two hours or more. If you think that is not demanding work, you are ignorant, stupid, or possibly both.

    But I guess a person like Jenos has a real need to look down on others. Perhaps that somehow helps him deal with the shortcomings of his own life. I like to remember something Muhammad Ali said – “When I started to have success, I resolved that no matter how high I might rise, I would view world without looking down on anyone.”

    A great man, Muhammad Ali.

    It’s worth noting that In & Out Burger pays better than the industry average and seems to encourage it’s workers to enjoy themselves on the job. When I go in I am always struck by the positive energy as opposed to other fast food joints. Maybe that explains why you have to fight just to get in the door and order lunch.

    Highly-rated. Helpful or Unhelpful: Thumb up 17 Thumb down 1

  131. anjin-san says:

    BK should do whatever the hell it thinks is in its best interest

    So as citizens of this country, should we all do whatever the hell we think is in our best interest, and screw America? Should we look for offshore tax dodges to avoid paying our fair share? Should a combat soldier pass on an opportunity to save his unit so he can stay at the bottom of a foxhole and avoid enemy fire? Should people with national security secrets start looking for the highest bidder?

    Typical conservative patriotism. As wide as the ocean and an inch deep.

    Highly-rated. Helpful or Unhelpful: Thumb up 20 Thumb down 1

  132. Ben Wolf says:

    @Jenos Idanian #13:

    BK should do whatever the hell it thinks is in its best interest. The people who are most upset at BK for considering this move already hate them already.

    Firstly, you are aware there is no person involved here named BK? The decision is being made by executives in control of a corporation called BK, and their interests do not necessarily intersect.

    Secondly, you are encouraging the looting of public wealth for enhancement of a few private bank accounts. If that’s all a business is for then there’s no reason for it to even exist.

    Highly-rated. Helpful or Unhelpful: Thumb up 22 Thumb down 0

  133. MR X says:

    @michael reynolds:

    You must be living in fantasy land if you think politicians are ever
    Going to pass laws banning these corporations from doing business with the government.
    That’s why they have lobbyists, aka as legalized corruption. People spend too much time
    Fighting over whether dems or repubs are right. The president like 99% of DC is beholden to
    Business interests. Do you really believe that anyone in DC wants legislation that may pay curb canpaign contributons? I don’t like it anymore than you do, but this issue is more to
    do with donors and lobbyists protecting their and their clients interests. The media should start scrutinizing these folks more instead of being such cowards

    Like or Dislike: Thumb up 4 Thumb down 0

  134. Tyrell says:

    Actually from what I have read, BK burgers are more pure beef than other fast food places.

    “Mm mm you can almost taste the hot dogs and french fries they sell
    Under the boardwalk down by the sea , yeah” (The Drifters, ’64)

    Like or Dislike: Thumb up 2 Thumb down 1

  135. Jenos Idanian #13 says:

    Working fast food is not demanding from a skill or knowledge perspective. But it can be a good way to learn and demonstrate other useful work skills, like reliability, honesty, endurance, patience, and managing pressure.

    @Ben Wolf: Firstly, you are aware there is no person involved here named BK? The decision is being made by executives in control of a corporation called BK, and their interests do not necessarily intersect.

    Does that even have a point? I referred to BK as “it,” and used it as a collective noun. Your comment here isn’t even nit-picking, it’s stupid and pointless nit-picking.

    Secondly, you are encouraging the looting of public wealth for enhancement of a few private bank accounts. If that’s all a business is for then there’s no reason for it to even exist.

    Judge Learned Hand:

    “Over and over again, courts have said that there is nothing sinister in arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich and poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions.”

    Considering how much money the government wastes, it’s hardly “patriotic” to give the obscene spendthrifts in Washington a single penny more than one is legally obligated to pay. And if one can improve one’s financial lot in a perfectly legal fashion, then there is nothing wrong with doing so.

    On the other hand, there is “bad” tax evasion. My favorite example is Rose Kennedy, upon whose passing she was declared a resident of Florida (where she hadn’t set foot in years) so the family wouldn’t have to pay Massachusetts inheritance taxes. Ted Kennedy didn’t think he should have to pay his “fair share,” and he got away with it.

    I assume that if BK does go through with this, they will actually move offices to Canada, unlike Rose Kennedy.

    Poorly-rated. Helpful or Unhelpful: Thumb up 0 Thumb down 15

  136. michael reynolds says:

    @MR X:

    Ah, facile cynicism. Seems so clever, doesn’t it. Just one wee little problem: your position is internally contradictory.

    If:

    1) The tax rate is too high and,
    2) Corporations have not managed to lower it, then,
    3) Congress is in fact capable of passing legislation in opposition to corporate wishes.

    Right?

    Like or Dislike: Thumb up 10 Thumb down 2

  137. anjin-san says:

    @ Jenos
    @ Jenos

    Working fast food is not demanding from a skill or knowledge perspective

    You don’t think there is any skill involved in running a register at Taco Bell when you have a 90 minute rush with a line averaging 15 people deep, that is peppered with impatient assholes? When one complaint could cost you your job? You don’t think that the manager of a McDonald’s has to actually know quite a bit to succeed?

    It’s pretty sad when you have to look down on a Burger King cashier to feel better about yourself.

    Highly-rated. Helpful or Unhelpful: Thumb up 17 Thumb down 1

  138. jukeboxgrad says:

    Pinky:

    why did that last comment get through without a problem?

    Good question. I have no idea. The bug has a seemingly random element, which is often how bugs are.

    Have you tried just putting in spaces or a hyphen?

    Thanks for the suggestion, but I don’t think that’s the right approach to fixing the bug. How would I know if it made any difference?

    Like or Dislike: Thumb up 3 Thumb down 0

  139. jukeboxgrad says:

    anjin-san:

    So as citizens of this country, should we all do whatever the hell we think is in our best interest, and screw America? … Typical conservative patriotism. As wide as the ocean and an inch deep.

    “The modern conservative is engaged in one of man’s oldest exercises in moral philosophy; that is, the search for a superior moral justification for selfishness.”

    -John Kenneth Galbraith

    Like or Dislike: Thumb up 10 Thumb down 1

  140. Grewgills says:

    On the other hand, there is “bad” tax evasion. My favorite example is Rose Kennedy, upon whose passing she was declared a resident of Florida (where she hadn’t set foot in years) so the family wouldn’t have to pay Massachusetts inheritance taxes.

    What makes her dodge worse than BK’s? Your standard was legality, both are legal. IMO, both are immoral. I am curious if you have a reason that one is more moral than the other that doesn’t involve political affiliation.

    Highly-rated. Helpful or Unhelpful: Thumb up 19 Thumb down 0

  141. michael reynolds says:

    @anjin-san:

    Well, Jenos is in the very sophisticated business of phone solicitation.

    Like or Dislike: Thumb up 9 Thumb down 0

  142. anjin-san says:

    @ Jenos

    I referred to BK as “it,” and used it as a collective noun.

    Which is incorrect, as a major corporation is highly complex, full of moving parts and often conflicting interests. Take for example, the interests of senior leaders who so often loot their own corporations in 21st century America.

    Years ago I was working for one of the first mega cell phone carriers. Pretty much everything we did while I was there was based on “getting the numbers in line for the IPO.” Shortsighted decisions were made to better position the company for the IPO. Employees were told they had to make sacrafices in compensation for the sake of the IPO. Important projects were delayed because of the IPO.

    Why was the IPO so important? Because a handful of people would have walked away with buy an island money after a successful IPO. The irony was that they had missed the IPO window, and refused to admit it. That did not stop the big boys from placing their own desire to go from rich to filthy rich ahead of the greater good of the company.

    Like or Dislike: Thumb up 11 Thumb down 1

  143. Ben Wolf says:

    @Jenos Idanian #13:

    I referred to BK as “it,” and used it as a collective noun.

    I’m aware you don’t get the point, given you’ve just repeated the error. Lashing out like a bum doesn’t make your argument seem better.

    Over and over again, courts have said that there is nothing sinister in arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich and poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions.

    The courts are not staffed with economists and do not understand that tax inversions will not result in one additional dime of prodictive investment, or that effective demand is the primary factor in investment. Every job eliminated reduces the total output of a society and leaves it poorer than it would otherwise be. The executives at BK have devoted themselves to acquiring as much government-issued currency as they may while avoiding contribution to the spending flows which enable the consumer transacrions from which they benefit. That means everyone else is left picking up the tab and

    Like or Dislike: Thumb up 10 Thumb down 0

  144. Ben Wolf says:

    @Jenos Idanian #13:

    I referred to BK as “it,” and used it as a collective noun.

    I’m aware you don’t get the point, given you’ve just repeated the error. Lashing out like a bum doesn’t make your argument seem better.

    Over and over again, courts have said that there is nothing sinister in arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich and poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions.

    The courts are not staffed with economists and do not understand that tax inversions will not result in one additional dime of productive investment, or that effective demand is the primary factor in investment. Every job eliminated reduces the total output of a society and leaves it poorer than it would otherwise be. The executives at BK have devoted themselves to acquiring as much government-issued currency as they may while avoiding contribution to the spending flows which enable the consumer transactions from which they benefit. That means the rest of us are left picking up the tab and watching our incomes fall as a result.

    Like or Dislike: Thumb up 7 Thumb down 1

  145. Jenos Idanian #13 says:

    @Ben Wolf: I’m still not seeing either of your points. In the first one, you don’t seem interested in spelling it out, despite two opportunities to do so, so I’m going to ignore it.

    In the second, you seem to be asserting that you have some kind of right to demand someone else pay for the things you want, and don’t like when you might have to pick up more of the costs of the things you want. No one — individual or group — has any moral obligation to do more than the law requires, and has every right to do things the law allows.

    One thing that has always made America special, in my mind, is that we don’t do a damned thing to keep people from leaving. Slave countries put up walls and fences to keep their people in; we do so to control who can come in.

    Like or Dislike: Thumb up 1 Thumb down 11

  146. michael reynolds says:

    @anjin-san:

    I once worked at Carl’s Jr. At the time I was in their management training program. (Just one of many sad episodes in my life.) By this point I’d managed diners, waited tables, and filled in working the grill. I lasted about three minutes expediting and assembling at Carl’s.

    Like or Dislike: Thumb up 9 Thumb down 0

  147. jukeboxgrad says:

    we don’t do a damned thing to keep people from leaving

    Well, not exactly. You are free to go as long as you understand you are not necessarily free to take all your money with you. There is such a thing as expatriation tax.

    Like or Dislike: Thumb up 10 Thumb down 0

  148. anjin-san says:

    we don’t do a damned thing to keep people from leaving

    Hey, they can go. And we can chose never to give them our business again. Freedom of action does not mean freedom from consequences.

    Like or Dislike: Thumb up 4 Thumb down 0

  149. anjin-san says:

    @ michael reynolds

    I never did any fast food work, but I imagine it can be just as difficult as any other restaurant work. I still occasionally have dreams where I have a packed bar and no matter what I do I can’t get a drink to a customer.

    Like or Dislike: Thumb up 3 Thumb down 0

  150. Jenos Idanian #13 says:

    @anjin-san: Hey, they can go. And we can chose never to give them our business again. Freedom of action does not mean freedom from consequences.

    Once again, you prove that you don’t read my comments, you just knee-jerk disagree — and usually in the most pointless way possible.

    The people who are most upset at BK for considering this move already hate them already.

    (Apologies for the repeated “already.” It wasn’t for emphasis, I’m still recovering from a very unpleasant illness.)

    Like or Dislike: Thumb up 0 Thumb down 6

  151. Ben Wolf says:

    @Jenos Idanian #13:

    In the second, you seem to be asserting that you have some kind of right to demand someone else pay for the things you want, and don’t like when you might have to pick up more of the costs of the things you want.

    This makes absolutely no sense, and appears to be a response to some argument being had with non-existent “generic liberal X”, given it has no relation to what I previously wrote. No one said anything about paying for anything.

    Societies have every right to determine what is and is not done with currencies which are, by definition and law, a product of government; they’re a public monopoly for public purpose, and they serve that purpose when they circulate. BK executives demand American society hand over a continuous stream of U.S. Dollars which they can then to remove from the U.S. economy at will; they want public wealth for private gain without the social responsibilities which accompany that privilege. BK executives did not create those dollars and do not have the right to dispose of them however they see fit.

    Like or Dislike: Thumb up 12 Thumb down 0

  152. C. Clavin says:

    So just off encouraging the slaughter of innocent children by Israel…BOOM BOOM BOOM…Jenos is now encouraging businesses to leave the US.
    Good times.

    Like or Dislike: Thumb up 0 Thumb down 1

  153. Rick DeMent says:

    One thing I have not yet seen discussed in this thread is regarding the notion that the US, unlike other countries, taxes profits abroad. You know what name me another country in the world that does the military heavy lifting that the US does. We have a military budget that gives a free ride to every other free nation in the world. There is a reason our budget is 27 times that of the next largest military power. Even if you calculate military expenditures per capita the US military outlays are over 4 times Canada’s. Every single time I hear the phrase “American interests” I translate that as Business interests. And that only covers military expenditures. Let’s not forget foreign aid, diplomatic services, infrastructure I could go on and on listing the money that is spent out of the US treasury that benefits multinational companies.

    So to answer Doug’s question if I think that sleazy accounting tricks like inversions are unpatriotic my answer is, of course they are. And anyone who doesn’t think so it a traitor to this sovereign nation and a more of a “socialists” then Barack Obama ever dreamed of being.

    I am absolutely sympathetic to the idea that the tax code needs to be changed but when you understand that the Republican party stands four squares again any changes that would solve this free rider problem WRT the role on the US military in keeping markets open and running around the world then the only objective analysis one can come to is that the Republican reactionaries are the bought and paid for whores who would seek to finance those institutions on the backs of the poor and the middle class for the exclusive benefit of those who profit the most individually from what is little more then legal tax evasion.

    Bottom line: it’s the conservatives and libertarians who are the one picking pockets, not the liberals.

    Highly-rated. Helpful or Unhelpful: Thumb up 20 Thumb down 0

  154. C. Clavin says:

    @michael reynolds:

    Jenos is in the very sophisticated business of phone solicitation.

    Every loaf of bread is the tragic story of grains that could have become beer, but didn’t.

    Like or Dislike: Thumb up 5 Thumb down 0

  155. anjin-san says:

    @ Jenos

    Once again, you prove that you don’t read my comments

    The people who are most upset at BK for considering this move already hate them already.

    I read this, I just considered it too stupid to respond to.

    Like or Dislike: Thumb up 6 Thumb down 0

  156. C. Clavin says:

    @Rick DeMent:
    Yes…+10.
    Our taxes make their overseas business possible/feasible.
    Our taxes make it possible for them to pay their employees poverty level wages, by providing public assistance to those employees.
    Yet they will shuffle papers to Canada to save 1% on their taxes…and folks like Jenos and Doug and Florack think it’s terrific.

    Like or Dislike: Thumb up 8 Thumb down 0

  157. MR X says:

    @michael reynolds:

    Not cynism but realism. I work in the private sector with financial institutions every day. Companies have 0 interest in having the tax lowered while they could pay practically nothing overseas. The US will never have a rate that can compete.

    Seriously, what do you think all these fund raisers are about?? You think these investment banks and hedge funds pay 32,500 just to meet the president because they like his policies. They do to it insure the status Quo while he just assures them all his words are just campaign rhetoric. He could Raise all their taxes today if he wanted to.

    http://www.slate.com/articles/business/moneybox/2014/06/taxation_of_carried_interest_the_loophole_for_hedge_fund_managers_could.html

    Like or Dislike: Thumb up 1 Thumb down 0

  158. george says:

    @Eric Florack:

    Say rather, that Canadas economy is booming in spite of single payer, not because of it.

    Actually, even the Conservative Party (Canada’s most right wing party) agrees that single payer is necessary. Some argue that there should be both single payer and private payer; almost no one (as in less than 5% of the population) wants to completely get rid of single payer. It works very well for life/death medical situations, though its not so good on elective surgery (which is why some want to supplement it with private payer for those cases).

    Canadians spend about half of what Americans spend on medical care (total spending, not individual payments), and have about the same outcome (including greater longevity). No one thinks that’s a bad thing. It might be better with a private supplement.

    And its amusing to read Americans worrying about one company moving a HQ to Canada; there are thousands of Canadian companies that have moved HQ’s to the US (mainly for reasons other than taxes of course – larger market presence being the main one).

    Like or Dislike: Thumb up 6 Thumb down 0

  159. michael reynolds says:

    @MR X:

    You make no sense. You see that, don’t you?

    If corporations are utterly dominant why wouldn’t they be able to get a lower tax rate? And if they can’t control that, then it follows that they would not be able to control a punitive law. So you’re taking two contradictory positions.

    Like or Dislike: Thumb up 5 Thumb down 0

  160. MR X says:

    @michael reynolds:

    Its all about Perception. The reason why corporations won’t be taxed close to zero is because there would be a populist backlash. Even if they were taxed at 15 or 20%, they would still Opt for the low international rate.

    and btw, please stop your condescending tone to me and others who disagree with you. You’re a retired senior living in Oregon while I’m in NYC working in the financial sector. You can read all the articles you want that affirm your views, but please stop pretending and lecturing people on the private sector and how political donations really work. If you are so inclined, can you can read that Slate article and tell me why Obama has not raised taxes on hedge funds as he has promised to do twice when he was running for president.

    Like or Dislike: Thumb up 1 Thumb down 8

  161. beth says:

    @MR X:

    If you are so inclined, can you can read that Slate article and tell me why Obama has not raised taxes on hedge funds as he has promised to do twice when he was running for president.

    You do realize that the president can’t just raise taxes all by himself right? That Congress actually needs to pass a law to do it? I don’t know where you’ve been for the last six years but Congress hasn’t given this president a whole lot of cooperation lately.

    Like or Dislike: Thumb up 12 Thumb down 0

  162. Rafer Janders says:

    @MR X:

    You’re a retired senior living in Oregon while I’m in NYC working in the financial sector. You can read all the articles you want that affirm your views, but please stop pretending and lecturing people on the private sector and how political donations really work. If you are so inclined, can you can read that Slate article and tell me why Obama has not raised taxes on hedge funds as he has promised to do twice when he was running for president.

    Well,I also live in NYC and work in the financial sector, and at least I know that it’s the Congress, and not the president, that sets the taxation rate. (And moreover that a GOP-controlled House isn’t going to bend over to help President Obama fulfill his campaign pledges).

    Like or Dislike: Thumb up 7 Thumb down 0

  163. C. Clavin says:

    @MR X:

    The reason why corporations won’t be taxed close to zero is because there would be a populist backlash.

    You are completely ignoring the fact that many corporations already pay zero…GE, Boeing, Verizon…the list goes on.

    Even if they were taxed at 15 or 20%, they would still Opt for the low international rate.

    In 2010 the average effective rate for corporate taxes was in fact 12.6%. We are a low tax nation…especially given the returns for those taxes. You endorse escaping taxes…while reaping the benefits they provide. Suppose everyone did that?

    tell me why Obama has not raised taxes on hedge funds as he has promised to do twice when he was running for president.

    Apparently you are unfamiliar with our Legislative Branch and how the process works here in America.
    Frankly it’s kind of humurous to watch you spewing totally fvcked up nonsense from your high-horse…while claiming to be an expert. Have you met Drew? Or I guess he’s calling himself Guanari now…

    Like or Dislike: Thumb up 10 Thumb down 1

  164. pylon says:

    @george: You are correct. Not only has the current Conservative party (in power for many years now) never made a single move against single payer, I believe the old Reagan pal Brian Mulroney called health care in Canada a “sacred trust”.

    Like or Dislike: Thumb up 8 Thumb down 0

  165. MR X says:

    @beth:

    It’s called “unilateral exercise of regulatory authority.” the president could do something, but he won’t. Not while there’s money to be made sucking up money from these companies to protect their interests. Or, maybe these people are just shelling out all this kind of money because they really approve of the president….

    http://www.bloomberg.com/news/2014-08-13/obama-donors-embrace-corporate-inversions-he-criticizes.html

    http://www.lohud.com/story/news/politics/politics-on-the-hudson/2014/08/26/obama-to-attend-2-westchester-fundraisers-friday/14669669/

    Like or Dislike: Thumb up 0 Thumb down 7

  166. wr says:

    @Jenos Idanian #13: “BK should do whatever the hell it thinks is in its best interest. The people who are most upset at BK for considering this move already hate them already.”

    And so Jenos applies his sole philosophy of life to business management — companies should only do things that irritate liberals, because that’s the only thing that matters.

    Like or Dislike: Thumb up 3 Thumb down 1

  167. MR X says:

    @C. Clavin:

    Ah, Clavin, the ultimate Copy & Paste guy who has never had an original thought. I thought you might have left this site after acting like such an ignorant prick in calling Robin Williams a Coward and your other stupid remarks on his death. Seriously, please don’t comment on my comments. I can tolerate disagreements and welcome debate with others, but I can’t take anything you take seriously unless you have Professor Bernius supervising you.

    Like or Dislike: Thumb up 4 Thumb down 6

  168. C. Clavin says:

    @MR X:
    So you got nothing? You could have just said that.

    Like or Dislike: Thumb up 3 Thumb down 1

  169. michael reynolds says:

    @MR X:
    I am neither retired nor living in Oregon. I’m a bestselling author of YA books (under pseudonym) pulling down high six figures and up. I live in Tiburon, CA, I drive a brand new Benz convertible and I’m married to another bestselling author. But I am sixty and thus a senior. So you got that much right.

    I condescend to people whose arguments make no sense. And particularly those who, once corrected, double down.

    Like or Dislike: Thumb up 12 Thumb down 1

  170. C. Clavin says:

    @MR X:
    Obama can raise taxes by

    “unilateral exercise of regulatory authority.”

    Gonna need to see a link for that one.

    Like or Dislike: Thumb up 6 Thumb down 0

  171. Scott says:

    @michael reynolds: I’m also 60 (and like you have a teenager at home). You can’t be a senior until you can get senior citizens discounts. Used to be able to get them at 55 but now they keep raising them just ahead of my advancing age. Bastards! Such is life.

    Like or Dislike: Thumb up 7 Thumb down 0

  172. steve q says:

    It doesn’t make sense that rational, fiscally conservative people would cheer a company scamming its fair share of taxes onto the rest of our backs.

    It does make sense that people who are motivated by simple dumb hatred of gummint would cheer a company scamming its fair share of taxes onto the rest of our backs.

    Like or Dislike: Thumb up 8 Thumb down 1

  173. MR X says:

    @michael reynolds:

    So you do live in fantasy land, writing young adult books. Living in wealthy Tiburion too driving a brand new Benz but you still have time for us little people and to knock those elitist 1%. I love the irony.

    Like or Dislike: Thumb up 1 Thumb down 10

  174. C. Clavin says:

    @MR X:
    Yeah…you’re jealous of Michael…we all are..but how about that link on how the President can raise taxes by

    “unilateral exercise of regulatory authority.”

    Like or Dislike: Thumb up 11 Thumb down 0

  175. Eric Florack says:

    @michael reynolds: The issue is not taxation per se’. The issue is at some point it becomes too much.

    If you have a restaurant, and your customer base is going next door do you make changes to make yourself more popular and stem the losses, or do you whine that your customer base is being “disloyal”?

    This Orwellian newspeak isn’t keeping people and businesses here, its helping to drive them away.

    Like or Dislike: Thumb up 1 Thumb down 7

  176. wr says:

    @MR X: So first you looked down on him because he was some poor white trash retiree in the back woods of Oregon while you lived the towering life of a financial genius in Manhattan. Now that he’s corrected you, you look down on him because he is far more wealthy and successful than you, and you are playing the self-pity card.

    And meanwhile you continue to refuse to back up your ludicrously ignorant statement.

    Quite an accomplishment today. Whatever will you do after lunch?

    Like or Dislike: Thumb up 11 Thumb down 0

  177. Eric Florack says:

    @anjin-san: Its called “FREEDOM”.
    I know that confuses you, so you may want to study the concept.

    Like or Dislike: Thumb up 0 Thumb down 9

  178. C. Clavin says:

    @Eric Florack:

    The issue is not taxation per se’. The issue is at some point it becomes too much.

    BK pays 27.5% and is moving to Canada where their rate will be 26.5%.
    So 1% is too much? Seriously?

    Like or Dislike: Thumb up 6 Thumb down 0

  179. Rafer Janders says:

    @MR X:

    So you do live in fantasy land, writing young adult books. Living in wealthy Tiburion too driving a brand new Benz but you still have time for us little people and to knock those elitist 1%. I love the irony.

    This word you use, “irony,” I do not think it means what you think it means.

    I don’t know if you know anything abou the publishing business, but the one thing it isn’t is fantasy land. Michael is, rather, a fabulously successful entrepreneur and small-businessman who every few months or years conceives a new product and brings it to market, all the while successfully building and maintaining his brand, and does it well enough to maintain a luxury lifestyle. If you actually are a finance guy I would think you’d appreciate how hard that is to do….

    Like or Dislike: Thumb up 11 Thumb down 0

  180. Jenos Idanian #13 says:

    @steve q: It doesn’t make sense that rational, fiscally conservative people would cheer a company scamming its fair share of taxes onto the rest of our backs.

    As noted above, BK will still pay 35% on its US revenues, even if the move goes through. What will happen is that they will no longer pay 35% on their revenues in other countries.

    I understand why so many people support taxing money earned in other countries, but I don’t agree with it. And I don’t see how “patriotism” is synonymous with “give the government more money than you have to so they can piss it away on stupid stuff.”

    But those of you who do equate that, may I ask just how much you overpay your own taxes to show your patriotism? May I assume that you don’t reduce your own tax burdens through such “schemes” as retirement plans, tax-free bonds, charitable donations, and the like? You wouldn’t be that unpatriotic, would you?

    Oh, and here’s a helpful link for the “patriots” here: it lets you voluntarily give money to the US Treasury.

    How do I make a contribution to the U.S. government?

    Citizens who wish to make a general donation to the U.S. government may send contributions to a specific account called “Gifts to the United States.” This account was established in 1843 to accept gifts, such as bequests, from individuals wishing to express their patriotism to the United States. Money deposited into this account is for general use by the federal government and can be available for budget needs. These contributions are considered an unconditional gift to the government. Financial gifts can be made by check or money order payable to the United States Treasury and mailed to the address below.

    Gifts to the United States
    U.S. Department of the Treasury
    Credit Accounting Branch
    3700 East-West Highway, Room 622D
    Hyattsville, MD 20782

    Like or Dislike: Thumb up 1 Thumb down 9

  181. C. Clavin says:

    @Jenos Idanian #13:

    BK will still pay 35% on its US revenues,

    No…they will not.
    According to BK’s annual report they paid 27.5% last year.
    Why do you consistently lie?

    Like or Dislike: Thumb up 12 Thumb down 2

  182. MR X says:

    @C. Clavin:

    Follow my comments moron. You’ll find it. Or use Google for a change. i can’t teach you how to think..

    Like or Dislike: Thumb up 0 Thumb down 6

  183. C. Clavin says:

    @MR X:
    So you got nothing. You could have just said that.

    Like or Dislike: Thumb up 9 Thumb down 1

  184. MR X says:

    @C. Clavin:

    You are lazy. Last time I post a Link for you. Read it or just STFU

    http://dealbook.nytimes.com/2014/06/12/how-the-president-can-increase-taxes-on-carried-interest/?_php=true&_type=blogs&_r=0

    Like or Dislike: Thumb up 0 Thumb down 5

  185. wr says:

    @C. Clavin: “So you got nothing. You could have just said that”

    He does. In every message he posts.

    Like or Dislike: Thumb up 7 Thumb down 3

  186. C. Clavin says:

    @MR X:
    You make a statement of fact…then to back it up…you link to an opinion piece that itself admits:

    it would not have the effect of taxing fund managers at ordinary income rates. Thus, it would hardly be worth the administrative headache.

    So you got nothing. You could have just said that,.

    Like or Dislike: Thumb up 8 Thumb down 2

  187. MR X says:

    @Rafer Janders:

    Am I supposed to be impressed by someone who has zero
    Respect for others with different views and who writes young adult books?
    No patience for condescending people, especially Northern California elitists which he is by
    His own definition

    Like or Dislike: Thumb up 3 Thumb down 10

  188. MR X says:

    @C. Clavin:

    Read the whole article. Obama has the legal authority

    Like or Dislike: Thumb up 1 Thumb down 7

  189. C. Clavin says:

    @MR X:

    Out of deference to Congress, the Treasury Department has traditionally avoided making policy in areas where the legislative branch may act.

    Like or Dislike: Thumb up 2 Thumb down 2

  190. Andre Kenji says:

    @michael reynolds:

    But I am sixty and thus a senior.

    If you lived in Brazil you could use the transit system for free.

    Like or Dislike: Thumb up 3 Thumb down 0

  191. michael reynolds says:

    @MR X:

    What you’re doing right now? That’s called flailing. Like a drowning man who can’t swim just splashes and waves his arms around and screams? Like that.

    Interesting, though. We have another great financial Master Of The Universe who comes around, and he also cannot construct a logical argument. I’m starting to wonder if it’s common to financial wizards. Walking into a board meeting spouting the latest buzzwords is not the same as presenting an idea for critical inspection by intelligent people.

    In terms of my work, as noted above, I am actually in a rather difficult business. The best available stat I can find is that there are 129,000 writers actually working as writers. By contrast, 1.2 million attorneys, about 350,000 stockbrokers, 690,000 doctors. In any given age cohort there are about as many lawyers graduating from the top four law schools as there are working writers. I’m a working writer, who has managed to earn law partner money for 25 years, and my work week? 20 hours, most spent on my deck looking across the water at San Francisco.

    Don’t pull the “I’m in business, I must be smart,” card unless you can back it up. In this forum rank is determined entirely by the force of your argument. I’ve been schooled here by guys who are half my age and make a tenth what I do, and they rule at that moment by virtue of having something to say and being right.

    Like or Dislike: Thumb up 13 Thumb down 2

  192. michael reynolds says:

    @Scott:

    My current concern is waitresses calling me “honey.” The first person to refer to my wife and I as a “cute couple” is going to be in a lot of trouble.

    Like or Dislike: Thumb up 6 Thumb down 0

  193. MR X says:

    @michael reynolds:

    I think you’re a fraud and just fos. Just because your liberal buddies worship you and
    Believe you doesn’t mean I have to. You guys believe what you want to believe. It makes you feel better spending most of your time conmenting on this site. I wouldn’t suspect a best selling author to do that, but then again I don’t believe you have wrote anything except what’s on the site.

    Like or Dislike: Thumb up 1 Thumb down 13

  194. C. Clavin says:

    @michael reynolds:

    I don’t believe you have wrote anything except what’s on the site.

    I think he just went down for the third time…glub, glub, glub…

    Like or Dislike: Thumb up 9 Thumb down 1

  195. Scott says:

    @michael reynolds: Yeah, I hear that. And I’m also glad that no one has yet referred to my son as my grandson.

    Like or Dislike: Thumb up 3 Thumb down 0

  196. michael reynolds says:

    @MR X:

    You make it so very easy.

    http://en.wikipedia.org/wiki/Michael_Grant_(young_adult_author)

    And a Twitter verification, just for you: https://twitter.com/MichaelGrantBks

    Like or Dislike: Thumb up 6 Thumb down 0

  197. michael reynolds says:

    @MR X:

    And I should add that Joyner is a Facebook friend of mine, so he can vouch as well.

    Like or Dislike: Thumb up 5 Thumb down 0

  198. michael reynolds says:

    @Scott:

    I had a weird one the other day. My daughter is Chinese-American and 14. Some woman at Bed Bath thought she was my wife. Simultaneously flattering and really creepy.

    Like or Dislike: Thumb up 7 Thumb down 0

  199. C. Clavin says:

    @michael reynolds:
    Did they call you Mr. Allen?

    Like or Dislike: Thumb up 1 Thumb down 0

  200. MR X says:

    @michael reynolds:

    Wow, i’m honored to debate such a distinguished author.

    Like or Dislike: Thumb up 0 Thumb down 5

  201. C. Clavin says:

    @MR X:
    Instead of being a class act and humbly admitting that you were 100% wrong and crediting him with his accomplishments…you choose sarcasm in a desperate attempt at self-aggrandizement.

    Like or Dislike: Thumb up 7 Thumb down 0

  202. wr says:

    @MR X: “especially Northern California elitists which he is by
    His own definition”

    I realize it’s fun to wallow in “little guy” self-pity, but weren’t you the one who was bragging about working with the financial big boys just minutes ago? Really, you can call yourself an elite or you can call yourself a little guy victimized by the elite, but you can’t have it both ways.

    Like or Dislike: Thumb up 12 Thumb down 1

  203. Mikey says:

    @michael reynolds: Win.

    And followed.

    Like or Dislike: Thumb up 8 Thumb down 0

  204. MR X says:

    @wr:

    I am an elite and don’t deny it. Damn proud of it too. I vote with my Wallet which means i vote for both Dems and Republicans. I don’t pretend to Care for other people and do whats right for the common good. I just point out and show you what I know and hear. It’s up to you to decide what you want to believe in. I believe in ideas and am not tied with any party like so many of you are. I just point out the hypocrisy of the system and how rigged everything is. I choose to be a capitalist because the alternative sucks.

    I originally posted my first comment on this thread with this which met most of the boards approval. I do have issue with nitpickers and people who condescend to others

    MR X says:
    Tuesday, August 26, 2014 at 16:04

    Whats with all the big fuss over this?

    It’s big companies using very expensive M&A lawyers to exploit loopholes. There’s nothing new here. Oh, I forgot its an election year so we’ll be hearing people chirp about this until November.
    then it will disappear for two years while the biggest companies contribute to both parties to keep the status quo.

    http://online.wsj.com/articles/how-tax-inversions-became-the-hottest-trend-in-m-a-1407240175
    ReplyReply

    Like or Dislike: Thumb up 7 Thumb down 0

    Like or Dislike: Thumb up 0 Thumb down 7

  205. Rafer Janders says:

    @MR X:

    I am an elite and don’t deny it. Damn proud of it too.

    So you have “No patience for condescending people, especially Northern California elitists which he is by His own definition” but we’re supposed to have patience for condescending people like you, especially New York City elitists which you are by your own definition?

    So it’s Northern California condescending elitists bad, NYC condescending elitists good? Or something else? Confusing….!

    Like or Dislike: Thumb up 13 Thumb down 0

  206. anjin-san says:

    @ Mr. X

    I think you’re a fraud and just fos

    No, Michael is exactly who he claims to be.

    You might try dialing back the anger and constructing better arguments. We already have a large enough amateur contingent here, your assistance in that area is not really needed. If you are who you say you are and not FOS, this should not be difficult for you.

    Like or Dislike: Thumb up 10 Thumb down 0

  207. Grewgills says:

    @Rafer Janders: @C. Clavin: @C. Clavin: @wr:
    While I don’t like the tone Mr X put on and don’t entirely agree with all of his argument all of you seem to be missing the meat of the links that support his argument on Obama being able to unilaterally close the hedge fund manager loophole. From the Slate link

    The hedge fund tax loophole wasn’t a bill that was passed into law; it was never voted on. It was part of a revenue procedure issued by the Internal Revenue Service in 1993, before there was any such thing as a hedge fund.

    The loophole wasn’t a bill that was passed into law; it was never voted on.
    According to Alan Wilensky, who in 1992 and 1993 was the acting assistant secretary of the Treasury for tax policy, the revenue procedure intended to clarify the tax treatment of some real estate investments. It defined a “realization event” as when an interest in a piece of real estate was sold or exchanged; if the event happened more than year after the real estate had been acquired, then the tax would be considered on a long-term capital gain.

    Later, when hedge funds started to come into being, the IRS applied the same revenue procedure to this completely different new financial device. No new ruling was issued—the old one was just assumed to cover it. This may have been understandable given the small number of hedge funds at the time, but by the end of the 1990s, hedge funds had become a wildly profitable and highly visible part of Wall Street. Robert Rubin, then Treasury secretary, could have asked for a new revenue ruling but chose not to address the new landscape.
    And there still has been no hedge fund–specific ruling on this matter. That’s why hedge funds could lose their tax advantage if only the IRS issued a new ruling saying so—no act of Congress required. The IRS is part of the Department of the Treasury. The secretary of the Treasury is appointed by the president and is part of his Cabinet.

    Certainly Republicans would howl about tyranny and socialism, but they’re gonna do that regardless of what he does.

    Like or Dislike: Thumb up 5 Thumb down 0

  208. C. Clavin says:

    @Rafer Janders:

    I am an elite and don’t deny it.

    I’v seen no evidence to support this:

    Like or Dislike: Thumb up 4 Thumb down 0

  209. C. Clavin says:

    @Grewgills:
    I could sleep with Kate Upton. I can’t sleep with Kate Upton.

    Like or Dislike: Thumb up 0 Thumb down 0

  210. MR X says:

    @anjin-san:

    I get angry when people dismiss my points reflexively. I dislike condescending people and don’t need to be lectured by people who won’t even have the courtesy to read my comments or links. I also hate people who aren’t polite just like the Talking Heads.

    At least Gregwills actually read my comments and i respect him for doing that. I’m not asking for anyone to agree with it or give me a thumbs up. i honestly don’t care, but if someone like Gregwills or Bernius makes a point or argument, I will read it and give it my honest opinion. If you don’t like my arguments, state why, but don’t embrace ignorance like Clavin and not at least have some intellectual curiosity to follow my link.

    Ad for elitism, I don’t pretend to be a champion of the people or some populist. i play the system because i have a family and the alternative sucks. l also don’t see a lot of fundamental differences between the GOP and Dems at the level where I am or the people I interact with on a daily basis. The definition of a politician to me is a skumbag. You pretty much have to be to get elected. One can not get elected without being beholden to corporate interests. A business can not get a good government contract without a lobbyist.
    politicians help. That’s just the way things work where I’m sitting.

    Like or Dislike: Thumb up 2 Thumb down 4

  211. Eric Florack says:

    @C. Clavin: As several have noted, the issue is far greater than that. You would be somewhat less icredulous were you to understand, as Harvey used to say, “the rest of the story’.

    Then again, it wouldnt do your argument any good.

    Like or Dislike: Thumb up 0 Thumb down 6

  212. C. Clavin says:

    @MR X:

    If you don’t like my arguments, state why, but don’t embrace ignorance like Clavin

    C’mon dude…I confronted your arguments point by point with facts that contradicted them
    @C. Clavin:
    and you responded with personal attacks and completely ignored the facts.
    @MR X:
    Your response to Reynolds embarrassing you tells us everything we need to know about you.

    Like or Dislike: Thumb up 3 Thumb down 4

  213. MR X says:

    @C. Clavin:

    Listen to Gregwills. He’s a lot smarter than you.. You’re the most intolerant person on here who also holds the dubious distinction of also being the most ignorant. Your the same guy who whines up getting thumbs down. Also the same guy who called Robin Williams a Coward. Remember that when even your buddies bashed you for being a moron. IT wasn’t too long ago. Do you want a link for that too?

    Like or Dislike: Thumb up 3 Thumb down 7

  214. C. Clavin says:

    @MR X:
    Again…no argument…no addressing the points made against you…just ad hominem attacks.
    IN other words…you got nothing. You could have just said that.

    Like or Dislike: Thumb up 5 Thumb down 2

  215. MR X says:

    @C. Clavin:

    btw, here is your link and the reason why everyone shouldn’t listen to anything you say. You not only lack knowledge but empathy.

    http://www.outsidethebeltway.com/robin-williams-commits-suicide//#comments

    Like or Dislike: Thumb up 1 Thumb down 9

  216. C. Clavin says:

    @Eric Florack:
    The quotes below are all yours…all talking about the evils of taxation.
    But when confronted with the fact that it only comes down to about one percent you…ignore that.
    It’s not about taxes…clearly…it’s about BK getting a breakfast product to compete with Dunkin’ and others.
    But you keep insisting on returning to taxes and big gubmint. Then confronted…again…with the fact that it’s just not that much tax…you ignore it…again.
    So…what does that tell you that you are unable to defend your position?

    when you tax the lifeblood out of businesses and make enemies of anyone with a profit motive

    Canada’s corporate tax rate in Ontario of 26.5% (the federal rate of 15% plus Ontario’s provincial corporate tax rate of 11.5%) is considerably favorable to the American corporate tax rate of 35%

    Lower than 26% for starters.

    theyd still be always on the lookout for a better tax deal

    Letting business do its thing without governmental micromanagement and over taxation

    What, after all, are taxes on businesses, but a hidden tax, which is passed on to and paid by “the working class”, in the form of higher prices? When the tax burden gets shifted to voters and they see clearly how much of our money is being taken to support Democrat utopia, what do you suppose happens to the left, hmmm?

    The issue is not taxation per se’. The issue is at some point it becomes too much.

    Like or Dislike: Thumb up 2 Thumb down 1

  217. C. Clavin says:

    @MR X:
    Yup…I said that.
    I said it based on the recent passing of my mother…and much of that process that I am unhappy about…and am still processing.
    In the ensuing discussions…both here online, and with friends who have personal experience with depression…I learned a lot.
    So yeah…I regret that comment.
    But here’s the thing…that doesn’t change a single thing about you, and who you are, my friend.
    Keep up the personal attacks instead of answering arguments. It’s working for you.

    Like or Dislike: Thumb up 6 Thumb down 2

  218. al-Ameda says:

    @MR X:

    Living in wealthy Tiburion too driving a brand new Benz but you still have time for us little people and to knock those elitist 1%. I love the irony.

    I believe it’s “Tiburon,” and, are you feeling inadequate today or something?

    Like or Dislike: Thumb up 4 Thumb down 0

  219. michael reynolds says:

    @MR X:

    Well, you’re on kinda weak ground complaining about people jumping to conclusions.

    That said, I’d remind you that my objection was to a single internally contradictory statement, not a general condemnation. Personally, I hope you continue to come around. And if you feel like you got beat up a little, well, everyone else here (very much including me) has been on the losing side at one point or another. It’s not fatal. This is one of the few places where one can trot out an idea and give it a test run, so to speak.

    Like or Dislike: Thumb up 9 Thumb down 0

  220. MR X says:

    @C. Clavin:

    You said that stuff because you’re an asshole not because of your dead mother. You only changed your tune when every single person who in remarkably rare agreement on here pretty much confirmed that you are a heartless bastard. That’s the real you and that’s why i give you Zero Respect and don’t care what you say. I know who I am and have no identity issues like you no matter how deplorable my existence may make you feel.

    So, we can continue this or you can stop trolling my comments and I’ll do the same. Have a lovely weekend!

    Like or Dislike: Thumb up 1 Thumb down 7

  221. C. Clavin says:

    @MR X:

    You said that stuff because you’re an asshole not because of your dead mother.

    You sir, have won the internet.

    Like or Dislike: Thumb up 5 Thumb down 2

  222. Ben Wolf says:

    @MR X: Not that he needs defending, but Michael overcame a rather disadvantaged life to get where he is and hasn’t forgotten that. He became a successful author, father and husband as well an all-around good guy despite setbacks in the first half of his life. Michael has earned more respect than you have shown him so far, although I am well aware discussions can become heated and we sometimes say things we don’t really mean. I’ve vehemently disagreed with him on a number of topics, but I’m still glad to know him and value his perspective (insofar as blogs let you know people, I suppose.)

    Like or Dislike: Thumb up 8 Thumb down 0

  223. MR X says:

    @michael reynolds:

    i considered your tone toward me condescending and dismissing. This may not of been your intent, but there are people on here who simply troll and immediately dismiss new and opposing views. i would have been content having a civilized debate with you, but your defenders kept trolling me and attacking me without trying to understand my point of view. Only 1 person on here was able to see my point even if they did not necessarily agree with it.

    Also, my last comment about you being a famous author was meant as astonishment and not sarcasm. I just didn’t find it believable that a famous author would spend much time on here. That’s your choice and you’ve worked hard enough to do and say whatever you want. I respect that and look forward to a more civil discussion next time.

    Like or Dislike: Thumb up 2 Thumb down 4

  224. michael reynolds says:

    @MR X:

    Yeah, this is what’s known as “avoiding work” for me. I’m especially likely to be here when I have rewrites (as I do right now.) I hate rewrites. Also it’s kind of a palate-cleanser, since the style of writing is so different.

    Virtual handshake.

    Like or Dislike: Thumb up 5 Thumb down 1

  225. MR X says:

    @michael reynolds:

    Virtual handshake = Agreed! Enjoy your weekend!

    Like or Dislike: Thumb up 3 Thumb down 1

  226. jukeboxgrad says:

    Jenos:

    here’s a helpful link for the “patriots” here: it lets you voluntarily give money to the US Treasury

    If defense spending seemed too low to you, would you send some extra money to the Pentagon? If you refrained from doing so, would that undermine your right to advocate higher defense spending? Just curious.

    Like or Dislike: Thumb up 4 Thumb down 0

  227. Jenos Idanian #13 says:

    @MR X: I’m probably the last person mr. reynolds wants endorsing him, but…

    I’ve called him a sociopath who’s freely admitted to hating Republicans and conservatives, but he’s also a very successful author in a very demanding field, and has quite a few other accomplishments to his name. I don’t like him (and it’s more than mutual), I don’t agree with him, I don’t respect his opinions, but he is exactly who he claims to be.

    Like or Dislike: Thumb up 0 Thumb down 0

  228. Jenos Idanian #13 says:

    @jukeboxgrad: If defense spending seemed too low to you, would you send some extra money to the Pentagon? If you refrained from doing so, would that undermine your right to advocate higher defense spending? Just curious.

    My argument for more defense spending has always been a matter of priorities, never total revenues. I’d prefer defense spending be offset with spending in other areas.

    The arguments presented here revolve around the total revenues aspect. So I’m asking those people who equate patriotism with paying money to the government to put their money where their mouth is.

    Or are you folks (those who are mad at BK) only generous with other people’s money?

    Like or Dislike: Thumb up 0 Thumb down 5

  229. C. Clavin says:

    @Jenos Idanian #13:

    The arguments presented here revolve around the total revenues aspect. So I’m asking those people who equate patriotism with paying money to the government to put their money where their mouth is.

    You’re arguing against strawmen……again.

    Like or Dislike: Thumb up 7 Thumb down 0

  230. anjin-san says:

    I’d prefer defense spending be offset with spending in other areas.

    Right. Lets’ cut food stamps (that lots of veterans and their families depend on) so that we can pour more money into the bottomless Joint Strike Fighter sinkhole.

    Like or Dislike: Thumb up 5 Thumb down 0

  231. Grewgills says:

    @C. Clavin:
    ???

    Like or Dislike: Thumb up 0 Thumb down 0

  232. MR X says:

    @Jenos Idanian #13:

    It’s all good. we squashed it. Enjoy your weekend!

    Like or Dislike: Thumb up 1 Thumb down 0

  233. wr says:

    @MR X: “I am an elite and don’t deny it. Damn proud of it too”

    And yet you whine that MR is… an elite. So are you an anti-elitist elite? Or just who will say anything when he’s so obviously losing an argument?

    Like or Dislike: Thumb up 1 Thumb down 1

  234. jukeboxgrad says:

    Jenos:

    My argument for more defense spending

    You didn’t answer the question.

    Like or Dislike: Thumb up 1 Thumb down 0

  235. Ben Wolf says:

    @anjin-san: I get the impression a lot of people don’t know that for a hundred years our economy has been dependent on large injections of government cash.

    Like or Dislike: Thumb up 6 Thumb down 0

  236. wr says:

    @MR X: “I dislike condescending people and don’t need to be lectured by people who won’t even have the courtesy to read my comments or links. I also hate people who aren’t polite just like the Talking Heads.”

    Here’s a hint, friend — no one here owes you anything, least of all the time it takes to read your posts. You want people to read what you have to say? Write something interesting. You want them to click a link? Make it appealing. It ain’t on us, it’s on you.

    Oh, and it’s not the Talking Heads who hate people who aren’t polite, it’s the psycho killer who is the subject of that song. If you’re going to bitch about people not reading you with enough care, you might start by showing some yourself!

    Like or Dislike: Thumb up 4 Thumb down 1

  237. C. Clavin says:

    @Grewgills:
    Anything is possible. It’s not possible.

    Like or Dislike: Thumb up 0 Thumb down 0

  238. Jenos Idanian #13 says:

    @jukeboxgrad: I answered your question. You just didn’t like the answer. Let me make it more directly:

    If defense spending seemed too low to you, would you send some extra money to the Pentagon? If you refrained from doing so, would that undermine your right to advocate higher defense spending?

    Yes, I would. But I’d reallocate it from existing spending, not from fresh income from me.

    I realize it impairs your argument to bring up facts, but the argument here isn’t about government spending priorities, but gross revenues — the fact that BK is taking perfectly legal action to reduce how much it pays DC. The argument being made is that “paying money to the government” is a form of demonstrating patriotism, by the inverse — that paying less money to the government is unpatriotic.

    If paying the legal amount of taxes due is unpatriotic, then one should properly demonstrate one’s patriotism by overpaying your taxes. I’m asking those making that argument to answer whether or not they are abiding by their own professed beliefs.

    Like or Dislike: Thumb up 0 Thumb down 5

  239. C. Clavin says:

    @Jenos Idanian #13:
    Holy fvck are you confused.

    Like or Dislike: Thumb up 1 Thumb down 0

  240. jukeboxgrad says:

    Yes, I would.

    This was my question:

    If defense spending seemed too low to you, would you send some extra money to the Pentagon?

    OK, so you would send some extra money to the Pentagon.

    But I’d reallocate it from existing spending, not from fresh income from me.

    OK, so you wouldn’t send some extra money to the Pentagon.

    Thanks for clearing that up.

    Like or Dislike: Thumb up 4 Thumb down 0

  241. Jenos Idanian #13 says:

    @jukeboxgrad: Not my fault you didn’t specify whose money I’d send to the Pentagon. I’d advocate for money being reallocated from other areas, as defense is one of the primary purposes of the federal government, but I’d not send any of my own. In fact, considering your normal expertise with language, I suspect your ambiguity there was deliberate. If so, it was a pathetic ploy.

    Besides, as you refuse to acknowledge, this issue isn’t about specific expenditures, no matter how you try to spin that. It’s about net revenues to the federal government. And there we run into a philosophical disagreement — I say that the government has plenty of money now, it just spends way too much in inappropriate ways. The counterargument is that the federal government doesn’t have a spending problem; that if we just give them more money, everything will be better.

    I reject that, and I reject arguments that present that position as a given.

    Like or Dislike: Thumb up 0 Thumb down 4

  242. anjin-san says:

    @ Jenos

    The argument being made is that “paying money to the government” is a form of demonstrating patriotism

    Once again, you are arguing with a generic “leftist” who exists in your mind. What I am saying, and what I think my fellow Democrats are saying, is that paying taxes is simply good citizenship. We all – businesses and individuals – enjoy the benefits of living in this advanced, stable society, and it costs money to provide those benefits.

    Do I use legal methods to mitigate my tax burden? Sure. But if I came up with a legal tax dodge that involved me adding a residence in Victoria, I would call that bad citizenship.

    There used to be a concept in this country called “corporate citizenship”, and we had perhaps our best days as a nation when it meant something.

    Like or Dislike: Thumb up 9 Thumb down 0

  243. anjin-san says:

    The counterargument is that the federal government doesn’t have a spending problem; that if we just give them more money, everything will be better.

    Ummm. No. This is the counterargument that the pretend Democrat that lives between your ears is making. He is probably being informed on what Democrats really think by Fox & Friends.

    Like or Dislike: Thumb up 7 Thumb down 0

  244. Yolo Contendere says:

    @Jenos Idanian #13: Probably a dead thread, but if you’re still around I’m really curious why you think Rose Kennedy is an example of “bad” tax evasion? She was living in and registered to vote in Palm Beach clear back when JFK ran for president, and lived and voted there through the 1980 election. I expect she would have continued to do so if she hadn’t had her stroke in early 1984, after which she went to Teddy’s house until she died 11 years later. She kept the Palm Beach house and continued paying taxes on it until she died, and very well may have hoped to go back if and when her health allowed her. She stayed on the voting rolls there. Moreover, according to your link she left everything to her trust, explicitly stating she and her late husband had done enough for the kids and assorted relations.

    I could see your point if this was someone who owned several houses, and specifically bought one they didn’t ever visit solely for the tax advantage of claiming to live there, or if someone was posthumously declared a resident of a state that she had no connection with, as you imply, but when it comes to someone who is at the end stage of life forced to live where they wouldn’t otherwise, I don’t see the benefit in forcing them to change their residency.

    Like or Dislike: Thumb up 9 Thumb down 0

  245. jukeboxgrad says:

    Jenos:

    Not my fault you didn’t specify whose money I’d send to the Pentagon.

    This was my question:

    If defense spending seemed too low to you, would you send some extra money to the Pentagon?

    Your own money is the only money you’re in a position to send, by definition. Thanks for yet another vivid demonstration of your legendary obtuseness.

    I’d not send any of my own

    Which demonstrates the double standard in your original statement (“here’s a helpful link for the “patriots” here: it lets you voluntarily give money to the US Treasury”). If someone who favors a policy of higher taxes is obliged to “voluntarily give money to the US Treasury,” then someone who favors higher defense spending is just as obliged to “voluntarily give money” to the Pentagon.

    Actually, neither is obliged, because advocating any given government policy does not oblige me to write a check expressing my commitment to that policy (aside from paying normal taxes). A simple concept that conservatives selectively misunderstand, as you have nicely demonstrated.

    I say that the government has plenty of money now

    FY13 revenue was 16.7% of GDP. Reagan’s average: 18%. Conservative hypocrisy is adorable.

    The counterargument is that the federal government doesn’t have a spending problem

    Spending is currently 20.4% of GDP. Average for the 20 years of Reagan-Bush-Bush: 20.8%. Reagan’s lowest number: 20.5%. Reagan’s average: 21.6%. The 40-year average is 20.5%. Spending as a % of GDP is barely higher than FY08 (20.2%), and it’s also not much higher than what Bush spent in FY06 (19.4%) when the GOP controlled both Houses of Congress and the unemployment rate was two points lower than it is right now. Conservative hypocrisy is adorable.

    Like or Dislike: Thumb up 5 Thumb down 0

  246. Jenos Idanian #13 says:

    @anjin-san: So, there are good legal ways to reduce your tax burden, and bad ways to reduce your tax burden. And you get to decide which are good and which are bad, which seem to overlap quite nicely with ways you use and ways you don’t.

    I don’t think “moral” has any place in arguments about tax laws — one should do what is legal, and arguments about what is “moral” depends on highly subjective terms. (Which, I note, tend to overlap the personal circumstances of the person making the “moral” argument.)

    You want to impose your sense of “morality” on people through tax laws? Apart from that being astonishingly immoral by my standards, feel free — through the laws.

    This is like the arguments about states refusing to set up insurance exchanges. The law presented them with a choice, and provided an incentive to chose the “right” way. Now a bunch of states made the “wrong” choice, and that’s causing problems.

    Here, the law gives corporations a choice — remain incorporated in the US, and pay taxes on their international revenues, or move to another country, and only pay taxes on their US revenues. You don’t like that they’re making the “wrong” choice, so they must be punished.

    You can’t get the law to enforce what you want, so instead of trying to change the law, you yell at them for obeying the existing law.

    But to repeat my earlier point: if one were to draw a Venn diagram of “BK customers” and “people most upset about BK’s possible move to Canada,” there would be almost no overlap. So why should BK care about, say, a threatened boycott from people who would never eat at BK anyway? It’s like me threatening to never buy one of michael reynolds’ books if he says one more mean thing to me. (Not only a judgment of him; his genre is one that has no appeal to me.)

    Like or Dislike: Thumb up 0 Thumb down 7

  247. anjin-san says:

    @ Jenos

    And you get to decide which are good and which are bad, which seem to overlap quite nicely with ways you use and ways you don’t.

    I don’t think “moral” has any place in arguments about tax laws — one should do what is legal, and arguments about what is “moral” depends on highly subjective terms.

    Did you not say that Rose Kennedy had used a “bad, but legal” method of avoiding taxes just the other day?

    Like or Dislike: Thumb up 5 Thumb down 0

  248. anjin-san says:

    @ Jenos

    You want to impose your sense of “morality” on people through tax laws?

    Do you never tire of inventing positions for other people?

    Like or Dislike: Thumb up 3 Thumb down 0

  249. anjin-san says:

    @Jenos Idanian #13:

    Ah, here we go, just a short while ago you said this:

    On the other hand, there is “bad” tax evasion. My favorite example is Rose Kennedy, upon whose passing she was declared a resident of Florida

    Now please reconcile that with this statement of yours:

    And you get to decide which are good and which are bad, which seem to overlap quite nicely with ways you use and ways you don’t.

    I don’t think “moral” has any place in arguments about tax laws — one should do what is legal, and arguments about what is “moral” depends on highly subjective terms.

    Perhaps you should find a blog where they let you use training wheels.

    Like or Dislike: Thumb up 7 Thumb down 0

  250. Grewgills says:

    @Yolo Contendere:
    I’ll give you a hint, it begins with a d and ends with an emocrat.

    Like or Dislike: Thumb up 0 Thumb down 0

  251. Yolo Contendere says:

    @Grewgills: I would not belong to the Emocrat party, on the off-chance they would have me as a member.

    Like or Dislike: Thumb up 0 Thumb down 0

  252. Jenos Idanian #13 says:

    @anjin-san: Here’s how it works: both Florida and Massachusetts have laws that define “legal residence.” And under both those laws, Mrs. Kennedy was a resident of the state she had not left — not even for a moment — for over a decade.

    Here’s Massachusetts’ legal definition of “residency” for tax purposes:

    An individual is a full-year resident if:

    his or her legal residence (domicile) is in Massachusetts for the entire taxable year; or
    his or her legal residence (domicile) is not in Massachusetts for the entire taxable year but who:

    maintains a permanent place of abode in Massachusetts; and
    spends in the aggregate more than 183 days of the taxable year in Massachusetts, including days spent partially in and partially out of Massachusetts.

    Note: A day in Massachusetts while on active duty in the United States Armed Forces is not counted.

    Spending over a decade in Massachusetts — a decade made up of full days — meets the “more than 183 days” quite comfortably. And staying at a family home for that long also qualifies as “maintains a permanent place of abode.”

    But it was the Kennedys, and it was Massachusetts. They didn’t want to pay the state what they legally owed, so they didn’t have to. And Massachusetts wasn’t going to enforce its law against the Kennedys.

    Like or Dislike: Thumb up 0 Thumb down 6

  253. Grewgills says:

    @Yolo Contendere:
    I can understand, the music is terrible and I’m not a big fan of black nail polish and heavy eyeliner.

    Like or Dislike: Thumb up 0 Thumb down 0

  254. Yolo Contendere says:

    @Jenos Idanian #13: But she wasn’t maintaining the permanent place of abode, Teddy was. She didn’t own the home, the family didn’t own the home, Teddy did. Now I suppose if she was paying rent to Teddy, she would be maintaining, but I would be surprised if that were the case.

    And again, she left it to her trust, explicitly not to her kids and grandkids. I haven’t been able to find out who benefits from her trust, but I don’t think she would have said in her will she had done enough for them if they were just getting the money by a different means. So I’m not sure why the family would have cared about some of it going to Massachusetts.

    Like or Dislike: Thumb up 6 Thumb down 0

  255. anjin-san says:

    @ Jenos

    I think you’ve beclowned yourself enough for one day.

    Like or Dislike: Thumb up 2 Thumb down 0

  256. bill says:

    @wr: comprehension, please.

    but seriously folks, this blog is in gun control/free contraception/white cop killing black mode now. who woulda thunk?

    Like or Dislike: Thumb up 0 Thumb down 4

  257. Just 'nutha' ig'rant cracker says:

    @Rafer Janders: He may not actually be a finance guy. He may only be Tsar Nicholas–you remember, the oil futures trading, logistical management, labor-relations arbiter/ lawyer/management consultant/entrepreneur.

    Like or Dislike: Thumb up 2 Thumb down 0

  258. Just 'nutha' ig'rant cracker says:

    @MR X: Actually, I’ve googled him. Mike Reynolds is the real deal and everything he says, if not more.

    I’m sorry that you are so insecure.

    Like or Dislike: Thumb up 2 Thumb down 0

  259. Just 'nutha' ig'rant cracker says:

    @Jenos Idanian #13:

    Not my fault you didn’t specify whose money I’d send to the Pentagon.

    Jeez…what are you, a fifth grader? You post a link about making contributions to the government, and that was the best you could come up with? “It’s not my fault…[that you didn't realize I was talking out of my rectal orifice]?

    Like or Dislike: Thumb up 5 Thumb down 0

  260. Ben Wolf says:

    @MR X: I’m glad you made that comment. Civility and willingness to acknowledge one’s errors are traits that cannot be given enough praise, and far too rare these days.

    Like or Dislike: Thumb up 2 Thumb down 0

  261. Eric Florack says:

    @C. Clavin:
    Oh, utter nonsense. as usual with you

    Brice, over at Q&O explains the additional factors I spoke of, this way….

    Matt Levine that makes the point that most in the media and almost all politicians opposing the merger fail to make:

    The purpose of an inversion has never been, and never could be, and never will be, “ooh, Canada has a 15 percent tax rate, and the U.S. has a 35 percent tax rate, so we can save 20 points of taxes on all our income by moving.” Instead the main purpose is always: “If we’re incorporated in the U.S., we’ll pay 35 percent taxes on our income in the U.S. and Canada and Mexico and Ireland and Bermuda and the Cayman Islands, but if we’re incorporated in Canada, we’ll pay 35 percent on our income in the U.S. but 15 percent in Canada and 30 percent in Mexico and 12.5 percent in Ireland and zero percent in Bermuda and zero percent in the Cayman Islands.”

    Got it? The US government does something no other first world government does. McArdle explains:

    The U.S., unlike most developed-world governments, insists on taxing the global income of its citizens and corporations that have U.S. headquarters. And because the U.S. has some of the highest tax rates in the world, especially on corporate income, this amounts to demanding that everyone who got their start here owes us taxes, forever, on anything they earn abroad..

    so, as usual, you leave stuff out that doesnt help your case.
    and by the way, Im writint this at a BK… breakfast is suprisingly good.

    Like or Dislike: Thumb up 0 Thumb down 3

  262. C. Clavin says:

    @Eric Florack:
    Again…for like the 8th time already…Every single one of those numbers is wrong.
    WRONG. WRONG. WRONG.
    Let’s see… Should I trust BK’s annual report…or a hack like Levin?
    If your argument is based on BS…then your argument is BS.
    Do you ever think that your inability to make your argument with…you know…correct information…might be an indication of the very basis of your argument?

    Like or Dislike: Thumb up 5 Thumb down 0

  263. C. Clavin says:

    @Eric Florack:

    And because the U.S. has some of the highest tax rates in the world, especially on corporate income,

    This too is just demonstrably wrong. Just because you wingnuts keep saying it doesn’t make it true.
    Here’s the fact…the average effective tax rate in 2010 was 12.6%….one of the LOWEST in the world. This is a low-tax nation. You will again refuse to address it but apparently that’s your thing.
    http://money.cnn.com/2013/07/01/news/economy/corporate-tax-rate/
    http://ctj.org/ctjreports/2014/04/the_us_is_one_of_the_least_taxed_of_the_developed_countries.php#.U_8Vaym9LCQ

    Like or Dislike: Thumb up 4 Thumb down 0

  264. C. Clavin says:

    @Eric Florack:
    You should be embarrassed that Levin tells you that BK pays 35% in the US and 15% in Canada…and you believe it without question. What kind of dupe are you?

    Like or Dislike: Thumb up 3 Thumb down 0

  265. anjin-san says:

    @ Florack

    Got it? The US government does something no other first world government does.

    Fails to provide universal health care for its citizens?

    Like or Dislike: Thumb up 6 Thumb down 0

  266. C. Clavin says:

    @anjin-san:
    Plays policeman for the entire planet?

    Like or Dislike: Thumb up 6 Thumb down 0

  267. C. Clavin says:

    @anjin-san:
    Provides US Treasuries…the safest investment available in any global investment market?

    Like or Dislike: Thumb up 6 Thumb down 0

  268. anjin-san says:

    Imprisons 2.3 million of it’s citizens?

    Like or Dislike: Thumb up 5 Thumb down 0

  269. C. Clavin says:

    @anjin-san:
    Deny Climate Change Science?

    Like or Dislike: Thumb up 5 Thumb down 0

  270. jukeboxgrad says:

    cracker:

    that was the best you could come up with

    And just to review, since this is so hilariously classic. Jenos said this:

    here’s a helpful link for the “patriots” here: it lets you voluntarily give money to the US Treasury

    And then I said this:

    If defense spending seemed too low to you, would you send some extra money to the Pentagon?

    And then he said this:

    Yes, I would. But I’d reallocate it from existing spending, not from fresh income from me.

    And this:

    Not my fault you didn’t specify whose money I’d send to the Pentagon … I’d not send any of my own

    So even though his original remark (“voluntarily give money to the US Treasury”) was obviously about “fresh income” from the person being addressed, he pretended to not understand that my question was about exactly the same thing, as if it wasn’t obvious “whose money” I had in mind.

    I appreciate the humor he provides, even though it’s roughly 100% inadvertent.

    Like or Dislike: Thumb up 5 Thumb down 0

  271. Andre Kenji says:

    Just a point: Burger King is controlled by 3G Capital, a company controlled by Jorge Paulo Lemann. Lemann became a zillionaire when he convinced the Brazilian government to help him to merge the two largest breweries in the country. Since then, Ambev, the company created after this deal, has been using anticompetitive practices, not only in Brazil, but on other Latin American companies. So, that´s crony capitalism at it´s worst.

    Lemann wants quick profit, and that´s one of the reasons why he can´t compete in really competitive markets( Take a look at his retail operations in Brazil).

    On the other hand, to me, it´s obvious that if you are going to operate in foreign markets you must understand that foreign culture. Simply doing cost cutting from above is not good management. The Scrooge McDuck School of Management only works on comic books. And you can´t operate in the consumer market and be seen as a tax dodger.

    Yes, the docile Brazilian media allows Pepsico to sell children´s beverage with detergent and with bacteria. But Lemann must understand that Canada and the United States are not Brazil.

    Like or Dislike: Thumb up 0 Thumb down 0

  272. C. Clavin says:

    @Andre Kenji:
    Look…from a business stand-point this move is a no-brainer.
    Tim Horton’s and BK are about the same size. So you have to make a decision where to base the business. Canada has a 1% cheaper tax rate…but that 1% is probably a good-sized chunk of change….but it’s no where near what some are claiming. So you move to Canada. Simple logic. 3G is Brazilian…they have no loyalty to America. They do benefit from America in their International Business…but so what…we are not going to feel the impact of this move.
    But we have to be absolutely clear…this move is only about donuts. BK is getting killed and it needs breakfast to compete. It’s business…plain and simple.
    To portray this as a condemnation of US tax policies and tax rates…as Florack and Jenos and Doug and Mark Levin and McArdle are…is pure and utter nonsense.
    We need to do tax reform…but to do that we need to have a real…fact based…discussion. That’s not ever going to happen with today’s Republican party constantly lying about tax burdens and tax rates.

    Like or Dislike: Thumb up 3 Thumb down 0

  273. Eric Florack says:

    it is when you consider all the factors.
    Like the US claiming tax on everything made in foriegn countries. the US is the only one does that.
    But then you being so superior would already know that, huh?

    Like or Dislike: Thumb up 0 Thumb down 6

  274. C. Clavin says:

    @Eric Florack:
    Eric…are you seriously unable to grasp this?
    Let me re-write the Levin quote with the real numbers.

    “If we’re incorporated in the U.S., we’ll pay 27.5% 35 percent taxes on our income in the U.S. and Canada and Mexico and Ireland and Bermuda and the Cayman Islands, but if we’re incorporated in Canada, we’ll pay 27.5% 35 percent on our income in the U.S. but 26.5% 15 percent in Canada and 30 percent in Mexico and 28% 12.5 percent in Ireland and zero percent in Bermuda and zero percent in the Cayman Islands.”

    Really? How many BK’s are there in Bermuda and the Caymans???
    Then you can add in the other nations…
    44% in France
    43% in Italy
    36% in Iceland
    32% in Israel
    32% in Poland

    THE TAX IMPLICATIONS ARE NOT THAT BIG A DEAL.
    It’s about donuts…not taxes.

    Like or Dislike: Thumb up 5 Thumb down 0

  275. Eric Florack says:

    @C. Clavin: apparently, theyre enough, for a lot of companies, to cover the costs of the deal, else we’d not be on the subject.

    Then, too, there is the principle of what the federal government is doing, which is, as another commenter put it….

    [I]t boils down to “the police kept people from sacking your first headquarters, so therefore you owe us 35 percent of everything you make, forever.” Loan sharks and protection rackets offer more reasonable terms than this.

    and, no, Clavin… its 35%.

    and look… at some point, to address anjins drooling, there is a point at which its patriotic, and good citizenship to oppose, or at least side-step a grasping, over-reaching government. since its their money and not yours, or the governments, they get to decide that point, and you dont.

    Think Boston Harbor as an example. tea, and all that.

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  276. al-Ameda says:

    @Eric Florack:

    there is a point at which its patriotic, and good citizenship to oppose, or at least side-step a grasping, over-reaching government. since its their money and not yours, or the governments, they get to decide that point, and you dont.

    Think Boston Harbor as an example. tea, and all that.

    I’ve always thought that Burger King was as American as Canadian Bacon.

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  277. C. Clavin says:

    @Eric Florack:
    It’s not 35%…until you provide a link that proves it.
    One that doesn’t come from your wing-nut friends.

    Our effective tax rate was 27.5% in 2013, primarily as a result of the mix of income from multiple tax jurisdictions and the impact of non-deductible expenses related to our global portfolio realignment project, partially offset by a favorable impact from the sale of foreign subsidiaries and a reduction in the state effective tax rate related to our global portfolio realignment project.

    http://biz.yahoo.com/e/140221/bkw10-k.html

    there is a point at which its patriotic, and good citizenship to oppose, or at least side-step a grasping, over-reaching government.

    Silly hyperbole. 27.5% is not over-reach…and the average corporate rate of 12.6% certainly isn’t.

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  278. jukeboxgrad says:

    Florack:

    a grasping, over-reaching government

    FY13 revenue was 16.7% of GDP. Reagan’s average: 18%.

    I already mentioned this, but like all good conservatives you are immune to all inconvenient facts.

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