David Morse @CentristinIdaho
Tax Policy Director @cpa_tradereform; Total Geek. Forbes Top 100 #TaxTwitter to Follow 2018-2021. All opinions are my own. RT not endorsement. prosperousamerica.org/david_morse Joined June 2010-
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@Khoon_Goh clearly distorts pharmaceutical trade. big hub for IP related trade too. a lot of profitable chip designers also used to have their tax HQ in Singapore so in certain products, yes, there is a big distortion
US imports from southeast Asia are clearly up. But how much has that really reduced US dependence on China? Consultancies extolling a shift really should look beyond the US data 1/ ft.com/content/ad0e35…
Yep. The migration of Apple's intellectual property from nowhere to Jersey and then into Ireland (and copycat moves) has generated some amazing distortions. 1/
Yep. The migration of Apple's intellectual property from nowhere to Jersey and then into Ireland (and copycat moves) has generated some amazing distortions. 1/
From the mouth of someone who used to help huge multinationals DO corporate tax avoidance: MN has a chance to stop it. This is a must read. The tax avoidance community knows that if MN does this, other states will follow. Let's make it so. @GriswoldDon startribune.com/dont-let-exper…
How dare we expect domestic companies to not have to compete with multinationals who have figured out how to avoid taxes. It's almost like we're not supposed to root for American manufacturing. m.startribune.com/dont-let-exper…
The $300b plus in profits that American firms report in low tax jurisdictions? That really should be part of the US tax base. 13/
We see this with big Pharma (the top 8 US companies). They pay about $3 billion in US tax (counting Gilead, which doesn't appear to offshore its profits anymore) and $11b abroad. Not only is the effective tax low, but the effective rate paid in the US is almost zero (3%) 10/
By building in strong incentives for GILTI structures and not tightening subpart F or blocking cost shares, US created IP ends up in tax havens and both the IP profits and the profits on production are taxed in the first instance abroad. 9/
It sets up another subsidiary in another low tax jurisdiction (typically in Ireland or Puerto Rico for the US, but sometimes in Singapore) -- It then sells the drug to its sales arm in the US at an inflated price. Hence large US imports of pharma in the trade data. 4/
Huge thanks to @tessturner17 for her help on this project (including reading a lot of 10-Ks). This is I think the one chart that explains it all -- big Pharma gets most of its revenue from the U.S. but reports almost all its profit abroad. 2/
My full written testimony on pharmaceutical tax avoidance and the "Pharma" Tax Cuts and "Irish" Jobs Act. Includes a set of specific policy recommendations that I didn't have time to spell out in detail in the actual hearing. 1/ finance.senate.gov/imo/media/doc/…
After decades of disastrous U.S. trade policy that promoted the offshoring of 🇺🇸 manufacturing, the U.S. faces a major vulnerability. We need a whole-of-government process to review offshoring of critical capacities & supply chains to foreign adversaries👇 prosperousamerica.org/cpa-applauds-r…
Re: comments & testimony at today's @SenateFinance hearing about whether TCJA or something else has slowed inversion, this piece suggests that primarily because of IRC section 965 (enacted or sought after), the real test for inversion comes Dec. 22, 2027. taxnotes.co/3HQSUJX
I actually intended to start with this chart (right now the same two charts repeat the start) Shows just how ridiculous the domestic/ foreign split of the reported earning of big Pharma is. The tax games are obvious to the naked eye. No fancy econometrics needed.
It not only seems bad. It is bad. There is no reason, other than naked tax avoidance, for the enormous differential between the US earning of US Pharma and the foreign earnings of US Pharma
🙌 Minnesota could be 1st state to address multinational corporate tax avoidance. In other words, make @Apple @amazon @abbvie pay taxes on income vs how they now play games & offshore the profits to magically pay little to no taxes. duluthnewstribune.com/opinion/column…
Seems like Apple, Microsoft and Big Pharma have decided to gift Ireland a sovereign wealth fund. 1/ ft.com/content/715069…
@CapozzolaSteven Well said @CentristinIdaho
Nothing scares foreign multinational companies more than American domestic companies standing up and demanding to end the tax avoidance games that hurt domestic competitiveness.
Nothing scares foreign multinational companies more than American domestic companies standing up and demanding to end the tax avoidance games that hurt domestic competitiveness.
Matt Foreman @ForemanTaxLaw
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Bro...
Disney CEO Bob Iger says: "[Marvel] had not been in the TV business at any significant level. Not only did they increase their movie output, but they ended up making a number of television series, and frankly, it diluted focus and attention." variety.com/2023/film/news…
A very bad look for @OECD @OECDtax - OECD pressed Australian Labor government to drop plan to reveal where multinationals pay tax. afr.com/politics/feder…
I could use some good vibes tomorrow morning if y’all have any to spare!
@CentristinIdaho @lalangboi the US should change its tax law! but right now it does accept it -- taxing only the residual intangible profit to get that rate up to 10.5% there are better approaches! finance.senate.gov/imo/media/doc/…
@henrysgao how about starting by looking at the tax incentives Singapore has extended to US pharma and tech companies, and examining whether in the process Singapore gave low tax rates to global IP as well as production in Singapore?
@michaelwan_cc Pretty sure tax is a deciding factor for a significant number of pharma and chip equipment/ design firms. Pfizer? Applied Materials? Qualcomm until recently. Broadcomm?
@Khoon_Goh clearly distorts pharmaceutical trade. big hub for IP related trade too. a lot of profitable chip designers also used to have their tax HQ in Singapore so in certain products, yes, there is a big distortion
@StephanieSoong @TaxNotes Thank you Stephanie! You too. 😄
taxnotes.com/tax-notes-toda… @StephanieSoong @TaxNotes Hope you had a great weekend! "The new global tax rules will have an impact on existing national tax incentive policies and present an opportunity for African countries to protect themselves from ceding their taxing rights.."
@werner_maryanne @TaxNotes Thank you MaryAnne! Have a lovely week!
From the mouth of someone who used to help huge multinationals DO corporate tax avoidance: MN has a chance to stop it. This is a must read. The tax avoidance community knows that if MN does this, other states will follow. Let's make it so. @GriswoldDon startribune.com/dont-let-exper…
p.s. Many thanks to all the tax experts who helped with the testimony. I obviously benefitted from the advice of @KClausing. But many others helped behind the scenes.
Busy day. I will offer clarification publicly on the context of this Chinese harassment which has become so normalized to myself and other dissidents that we even forget that others find such information shocking. Trust me there are far worse actions than what I publicly shared
@RichardRubinDC yes, absolutely. US should get a ton of revenue out of pillar one and pillar two from pharma, especially if pillar two leads some of the cost shares to unwind and move out of GILTI based structures to structures where the IP at least is taxed in the US at 16 plus (after 25)
Pharma is just an especially obvious example -- out of the $110-115 the big 8 US pharma firms earn in profit (counting Ely Lilly and Gilead even tho their data is incomplete), the US appears to have only collected $3b in tax revenue. 14/
The $300b plus in profits that American firms report in low tax jurisdictions? That really should be part of the US tax base. 13/
We see this with big Pharma (the top 8 US companies). They pay about $3 billion in US tax (counting Gilead, which doesn't appear to offshore its profits anymore) and $11b abroad. Not only is the effective tax low, but the effective rate paid in the US is almost zero (3%) 10/
By building in strong incentives for GILTI structures and not tightening subpart F or blocking cost shares, US created IP ends up in tax havens and both the IP profits and the profits on production are taxed in the first instance abroad. 9/
But what shows up in the disclosure of the big Pharma companies? Big profits in low tax jurisdictions; and next to no profit in the US. AbbVie's US operations consistently "lose" money. Pfizer's did too before the vaccine. 6/
US consumers pay about 3.5 times as much as the rest of the OECD for patent protected meds (per a recent Rand study) -- and the cost of making a drug is constant, so the US should be the main source of the profits of big Pharma. 5/
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