Posts by I ain't Spartacus

Re: Pointless

Europe still gets its pound of flesh though, as this is a past liability.

Also Ireland have half the corporation tax of Germany or France, so for the EU single market, it still makes sense to book all the profits from Europe in Ireland. That is assuming Trump sets the rate at 10% for foreign profits but keeps the domestic one at 35%. If he sets everything at 10%, then they're better off operating entirely from the US.

Re: Why was that "rubbing salt in the wound"?

DougS,

Well no. Irish Corporation tax is still 12%, compared to the US 35% - so there's still a good reason to shelter the cash abroad. Even the UK's 20% rate is still a lot nicer than 35%.

Also, they can't get out of paying this - it's a past liability - but it makes no difference to their deferred tax liability to the US, as it can be offset.

This problem is entirely of the US government's own making. They allow deferral of corp tax payments on foreign profits, they demand payment on foreign earnings (to be fair with offset against tax paid abroad in most cases), and they have both high corporation tax and high dividend tax - so it costs something like 70% in tax on dividends. They've created a system of eye-wateringly high tax that can be trivially avoided indefinitely - what the hell did they expect.

To make it worse Bush, and I think Clinton, both had foreign profits amnesties, where they could be repatriated at lower tax rates. So there was another incentive for large corporations to sit on the cash and wait. Now Trump's in - they may get a lower rate - assuming he can avoid falling out with the rest of the Republicans.

Re: Political theatre only

Well a €13 billion windfall isn't such a bad thing to be blamed for...

But as you say, they may feel they've got to be seen to object. And also partly for domestic politics. If they admit they were in the wrong, they're admitting to their taxpayers (after years of huge austerity and a more than 10% drop in the size of the economy), that they could have had €15 billion of extra. And that's serious money in a country with a small population.

The judgement is against the Irish government. The EU has no jurisdiction on Irish corporation tax, that's a local matter. But they do have jurisdiction on illegal state aid. Which is the case that Ireland lost.

Some people have accused the Commission of cheating or mission creep. Of ruling on an area that's the sole competence of governments - but I don't think that's fair - because they've ruled on a specific deal, where Apple were allowed to create a company to hold profits that on paper had no geographical location, and so paid no corporation tax to anyone.

Re: Politicos covering their backs...

Apple were paying Irish corporation tax on their Irish profits. But were allowed to book a huge chunk of their global profits to an "Irish" company that didn't have a link to any state - and therefore didn't owe any tax. Weee! Nice wheeze. This was changed last year, and was one of the causes of a startling rise in Irish GNP - along with presumably other companies coming off the deal.

Now Apple would still have paid that tax to the US - had they ever chosen to repatriate profits. Because the US charge tax on global income (though you can usually offset the corp tax you pay abroad against this). But that's why Apple were borrowing money in the US (and so paying interest on it) to pay their dividends, so as not to repatriate any money and pay US corporation tax.

Many other EU countries have been trying to persuade / force Ireland to up it's Corp tax level to more like everyone else's 20% (ish) for years - because they see it as unfair that Ireland poaches corporate HQs off them. But that's how the single market works. What's really annoyed other governments is that not only were Ireland "stealing" their corp tax take - but worse they were then giving it away for free. And that's what the ruling stops.

I can't see Ireland winning on appeal, for two reasons. Firstly because they've already changed their tax system, which sort of admits they knew they were going to lose. Secondly the European Court is unlikely to overrule the Commission on something like this, because it's not a proper independent court - it tends to support the same political aims.

Apple rubbed salt into the wound by announcing they were going to repatriate a bunch of money to the US under a week after the decision. That being just enough cash that the US corporation tax would be offset against the EU bill. If they do win on appeal, who wants to bet they'll suddenly find a reason not to repatriate that $40bn?

Re: A bridge too far

True. But then I dislike doing the VAT return. But as I'm paid to do it, and HMRC will come and get all grumpy with us if I don't, it gets done.

I would use Facebook. If you paid me.

Re: two tribes

Nah. These forums are gentle and fluffy. I wouldn't characterise them as full of monsters at all.

The warning should be more like: Here be grumpies - get off their lawns!

Re: I wouldn't be recruiting today

wolfetone,

I really don't think so. I suspect you'll find Hillary won't be sending any more emails for a while. Snail mail or carrier pigeon only for her from now on. She tried sending emails, but it didn't work out so well...

Re: Why the fuss?

We'll all notice when the Moon hears of this, and starts wearing its red pants and blue spandex suit with the big S on the front.

Re: Media and entertainment

Yes, it sets precedent - and it's worth noting here that the precedent would be one which granted the government a lot of power to overrule parliament in the future. A very dangerous precedent, in other words.

I disagree.

It doesn't really set a precedent, because this is a unique situation.

So unique in fact that the High Court are already creating precedent, by trying to invent law where there is none - because the law in question was badly drafted.

Basically Article 50 says we leave automatically in 2 years if no deal is unanimously agreed to extend it (or make it quicker). It also says that it's invoked by the government in question, in accordance with their own rules.

But when this was put into UK law as part of the Lisbon Treaty (European Constitution MkII), I don't think Parliament bothered to specify what those rules are, as they didn't expect to be leaving.

So the court had to make up the law, as there wasn't any. It's clear that government gets to negotiate treaties, and so negotiating our leaving deal is down to royal perogative. Parliament can advise, and be kept informed, but get no say until there's a final deal done, to put into UK law.

But the court asked, is A50 irrevocable? The government said yes. Once triggered we're automatically out of the EU after 2 years. I'm sure it could be fudged, but only if all other 27 members agree - and probably the European Parliament too. That's unlikely, so we'd be out in 2 years.

Well in that case, the court said, Aricle 50 is effectively repealing the European Communities Act because it inevitably leads to that, once we trigger it. Hence Parliament has to have its say first, as that effectively will be repealing legislation and removing rights from citizens, which must be done with Parliament's assent.

On the letter of the law, the judgement is dubious - A50 isn't changing UK law at all. It's a use of an exisiting treaty power, already created by Parliament, involving treaty negotiation which is a perogative power. However once the court asked if it was inevitable they went with the logical ruling, that it's effectively changing the law. After all, Parliament could refuse to repeal the act taking us into the EU, but what's the point of that if triggering A50 means they've kicked us out?

Re: @I ain't Spartacus

I believe it's a (really stupid) EU directive, so come Brexit we can have our fire extinguishers back in black, blue, cream and red - as God intended.

Not sure what colour whatever less ozone-unfriendly chemical passes for Halon these days should be tbough.

My area only has some PCs and lots of paper files, so we've got the right stuff. I believe we have to have 3 because we don't have a fire escape on this floor, so we've got to be able to get down the stairs to the one below.

Which incidentally leads into the stockroom of the rather expensive HiFi shop next door. I'm tempted to stage a small fire, and see if I can't liberate me some tasty speakers while "escaping".

I know someone who's a retired skipper for Saudi Aramco. Or one of their more boat-y subsidiaries. Strangely enough when you captain a 200,000 supertanker, you get quite a lot of firefighting training. His rule is that the law can go hang - any extinguisher on his boat will be painted the proper colour - so it can be identified at a glance.

Re: Tossing water at electric fire

I remember having to point out to someone that CO2 was fine for a small enclosed kitchen, but that Halon was definitely a bad idea.

The estates management people in our current office came around and re-did our extinguishers this year. There are only 2 rooms on the top floor, and I've now got 2 water and a CO2 extinguisher to play with. Which snazzy glow-in-the-dark tops on.

Which would be great if they weren't all now stupidly painted red - so you can't tell them apart without looking closer. If they wanted to do that for visibility, they should have mandated a band of colour at the top - so you could easily tell the type.

Re: All according to plan

I've got some news for you. There's no such thing as a free lunch. If you save your money with a bank, you are lending it, at risk. The risk being the bank going pop, and you losing your money.

Interest rates on bank loans are lower, because the risk is very low. But there's still a risk there. Had QE not happened, those with savings would have lost everything. So don't complain too much about QE - it did it's job.

BTW QE is not money printing, in the normally accepted meaning of that phrase. The difference is technical, but real. Basically because it's a temporary effect tied to the short-term purchase of an asset from the market, that will later be sold back into the market and the central-bank created money is then destroyed. The job is not to create money but to create liquidity - and stop the economy seizing up. It worked.

The 2nd job of QE is to force interest rates down, so that those holding lower risk assets are forced to either take more risks, or accept small losses.

However complaining about the shocking inflation of 0.5% (expected to rise to 1.5% next year) is pretty bloody laughable.

One of the major causes of the recession was over-saving. Not by UK households, we borrowed too much, but by the world's main exporters (basically OPEC, Russia, East Asia and Germany). They poured cash into the money markets rather than spend it themselves, or let their currencies appreciate sucking in imports - and this caused a huge global imbalance. This was one major cause of the borrowing/banking boom - and subsequent bust. QE was trying to force unproductive assets to be moved into investment in the real economy - to try and force economic growth. This is the bit of QE that hasn't worked as well, it's led to more of an asset boom than an investment boom.

But as QE saved the banking system, and so the economy, and kept deflation away - it was a great idea.

Re: Benefit for both?

Well part of the corporation tax problem is the single market. Also the VAT problem. The point of the single market is that a company in one country should be able to trade in another, but using its normal domestic legal regime.

So that encouraged countries to game the tax rates in order to attract more corporate HQs.

In principle, Brexit (assuming we also leave the single market) would fix that problem. However, corporation tax avoidance is also something large corporations, with large profits to pay lawyers and accountants, are always going to do.

I don't think corporation tax stealing works so well for large economies. By lowering the rates to attract a few more HQs in, you lose money from your exisiting companies. But if you're a small market like Ireland, with foreign trade making up a huge proportion of your economy, it's worth doing.

Re: finally a brexit benefit (for EU)

Must be working through the pile of things uk blocked right now.

I bet you it wasn't just the UK that blocked this one last time. So it still might get blocked.

But there are certainly a bunch of things we didn't want where the EU went ahead without us. The two biggest being Schengen and the Euro. How are they turning out?

Well, Schengen is currently in the process of breaking down - the Commission just had to decide not to sanction a bunch of countries for using "temporary emergency" border controls for over a year so far for example.

And the Euro has turned out to have been one of the greatest fuck-ups in modern economic history. Italy's economy is smaller than it was when the Euro began - their manufacturing sector is now smaller than it was in 1992. Greece has suffered a longer and deeper recession than either Germany or the US did in the Great Depression - and Greek unemployment is predicted by the IMF to finally drop below 10% by 2040! The whole Euro area is flirting with deflation, unable to politically resolve these difficulties, the economy is still smaller than when the recession hit in 2008 and the banking system is in a horrible mess, and there's no political solution in sight.

Perhaps they should have listened to us a bit more...

Re: Courriel

On the other hand, le ferry-boat is an abomination.

But there's nothing wrong with le sandwich, le weekend etc.

I was a bit doubtful of cliquez (as in "cliquez ici" for click here) - it's a bit ugly. But then tirez (shoot) isn't much better.

Packaging in Belgium was even more fun, as it was often double-sided French/Flemish, sometimes with extra German, Italian, English. But then you got random yellow bits on the packaging saying "New Improved" or "50% extra" and it was random as to what language they'd pick for that as well.

And their supermarkets often had TVs by each checkout showing techno and europop. Which is just evil.

Re: Could still happen after Brexit

Plus we've got some of the top research universities in the world and so can either remain in the EU research programs (maybe sweetening the deal by upping our budget contribution by a few million) - or if they don't want to play then simply reallocate our share of that budget entirely to our own academics.

As we're a net contributor we can easily replace any EU funded thing ourselves, given we already fund it at the moment. As that's the meaning of net contributor. And there's still money left over that we already pay out to either bribe the EU to agree to continue doing stuff we want (and keep the existing EU budget) - or take back and spend on doing other things.

Brexit would have got get very unfriendly indeed for academic cooperation to stop - I'm sure there are more important things to worry about.

Re: One small step...

This is what farmers will buy it for.

It'll play a recording of "Gettt orrff my laaaand" - then shoot you with the shotgun they've just replaced the laser with.

Re: Pulsed agrilaser in the 40W range

Thus, getting a cat will not eliminate or keep other cats away, it will simply cause your property to be time shared.

What about if you get a lion?

I admit you may be introducing an even worse poo problem. Although I believe you can sell it to other people to put in their gardens to keep cats away. There's also the problem of food, they're not cheap to feed, and if you're really unlucky, you may be on the menu yourself.

Re: Those of us old enough to remember . . .

Either they're testing this near my office, or they should be. A pigeon flew down the chimney next to my desk this morning, and perched on the back of one of our swivel chairs.

The windows don't open very wide, so I was expecting a bit of a struggle to get the bugger out - and a laser would have come in useful for that too. Managed it with the minimum of flapping and shitting - either from pigeon or me.

Seems like a better solution than random slaughter of wildlife though.

Re: A-10 role

Helicopters are regarded as ground forces, partly because they're so often tightly integrated with ground troops, but also because they fly lower and slower - and so are much more vulnerable.

Helicopters also don't like high altitude or high temperatures (both massively reduce their fuel and weapons payload).

Hence Harrier did lots of close air support for the UK in Afghanistan, until it was ditched - because it's good at going slower than fast jets, and still carries loads of stuff.

I think the brass see drones as the future of close air support. You can make them bigger, and carry more stuff, or just have more of them. You don't mind as much when they crash - and you can also take higher risks with them. Plus you can have them loitering near the enemy gathering intelligence, then drop weapons when required.

Re: A10 the Meccano airplane

Well anything we've got in service could have easily dealt with Assad's airforce. It was politcal will that was lacking, not hardware.

Harrier, Jaguar and the A10 were designed around the same time to do the same job, close air support on the front lines in Germany - where decent runways were going to be in very short supply, if not actually covered by mushroom clouds. Logistics was also going to be a right old mess. Their job was going to be supporting the forward troops to keep them alive long enough for NATO to mobilise and get troops there before the front lines collapsed totally. The mainly Germany, British and US professionals on the border weren't expected to last many days into WWIII - even if it didn't go nuclear. I don't think there was much hope held out for the close air support either.

Re: A10 has a unique role doesn't it?

I'd imagine the future of close air support is seen as drones. The close bit of it meaning that you expect higher pilot losses than any other type of mission. Current drones aren't up to it of course, they're great for hours on end of recce and the odd missile strike - but don't compare to what the A10 can do.

For some reason nobody seems to believe that they can knock out a few hundred of a new design all that cheaply anymore. How much that's down to the defence industry, the requirement for things to be every shinier or the fact that nodody can write a decent spec and stop bloody tinkering with it is a matter for the reader to decide...

It's been done with armoured vehicles in Afghanistan and Iraq when the US Hummer and UK Landrover were totally inadequate. So why not planes? One of our light recce vehicles (the Jackal I think) was designed, tested and into first production in 18 months.

The downside of the huge multi-role plane project is that it becomes a monster, as it's expected to do so many jobs.

The downside of having multiple weapons systems is that you need multiple supply chains - which makes logistics and training much more expensive and difficult. Whether 10 years is really enough to replace the A10 with drones seems very doubtful to me though.

Re: Right tool for the job

Nope. I think you misunderstand the Bigwigs. If the senior officers of the US airforce (or the RAF for that matter) had wanted to spend their time helping squaddies - they'd have joined the army. But they didn't, they joined the airforce, because they like fast planes that are pretty. They like flying them, and they like getting budget so lots of them keep flying. And they like even bigger budgets to buy newer, shinier ones. They only buy ground-attack aircraft when forced to at gunpoint. And even then, they'd much rather spend that cash on a fancy new fighter or strategic bomber, and then do a ground support version later.

To be fair, the B52 makes an absolutely awful strategic bomber nowadays. At least, against anyone with an airforce. But it can carry an awful lot of laser guided bombs, and hang around for an awfully long time, so squaddies with laser designators can have bombs when they need them. So they are willing to compromise.

But sometimes, nothing beats a fucking enormous cannon strapped onto the front of an incredibly ugly aeroplane. Which carries a big bunch of bombs as well, just in case.