No Boris, ain’t gonna happen

Omigosh – what a contest; and what a dilemma for us all! Your eyes flit desperately between them, and for many people it will be an eerie feeling: the first time they have ever been tempted to side with Brussels over anything. Margrethe has made an extraordinary demand. She wants Apple to pay the Irish state an infarct-inducing sum in back taxes – between $8 and $16 billion, and I know that many of you will egg her on. Yee-hah, Margrethe, you will be saying. Go on, darling. You fine them. You tax them. You show those overmighty Yankee tech giants that someone, somewhere, will finally stand up to them.

I’ll happily bet dollars to donuts (just thinking about it, that’s a rather old phrase now, isn’t it? Given that donuts do actually cost dollars now?) that it’s not going to be anything like that. Couple of hundred million to cover a decade, perhaps. But billions? Nope.

85 thoughts on “No Boris, ain’t gonna happen”

  1. Johnson is one of the worst self-serving POS BluLab hacks in existence.

    There is no evil or moronic cause he would not put himself forward in and speak for–if he thought he would gain some personal advantage from it.

  2. Bloke in North Dorset

    I remember when the political debate would be around ideas for helping the poor and needy, however misguided their policies. Now it seems to be around who can fuck up the economy fastest through sheer ignorance.

  3. I did read the article.

    He is trying to be on both sides at once. Having designated the “capitalist” side as equal in super-villainy to the EU.

    He is an EU shill. Seem to be sort of anti-EU but not so much as to upset the BluLab hierarchy. He tries at least to seem to be all things to all people. But sort of suggests that he is really sort of against Brussels–really. And then –on the eve of the Referendum declare that –on balance–he is in favour of staying in.

  4. Well, yes, abacab, the quoted passage is clearly sarcastic in the context of the article, and he does defend nations’ tax sovereignty. But he’s still clearly in the camp of multinationals should pay more. And his defense of the low Irish tax rate is a bit snarky.

    It was their sovereign ambition to attract the HQ of Apple and others. They wanted Irish taxi drivers to have the honour of ferrying Apple executives around, and they wanted Irish waitresses to snaffle their huge tips.

    So, creation of local jobs is a bad thing now? I’m sure that Apple Eire employ plenty of locals directly as well. Apparently this is all demeaning somehow.

    He nails his colours firmly to the mast at the end.

    We want, need and deserve these companies somehow to pay more tax in the UK.

    So not the best quote perhaps, but the only way he differs from Brussels is in who should make the demand.

  5. Well Apple have provided me with a phone and a computer that have improved my quality of life immeasurably. The EU have been nothing but a pain in the arse. I know whose side I’m on. Apple can pay bugger all tax as far as I’m concerned.

  6. I’m also a little confused by Boris’ link within his own article regarding Margrethe Vestager’s plan’s. It appears to be an article about an order for Belgium to recover sweetheart tax breaks given to large (mostly European) corporations at the expense of smaller companies. Doesn’t mention Apple or Ireland at all.

    http://www.telegraph.co.uk/finance/newsbysector/industry/12092808/Belgian-sweetheart-tax-deals-are-illegal-says-EU.html

    So does this example that Boris is talking about exist at all? Or is the entire thing made up out of whole cloth?

    (abacad – read the whole *linked* article as well as the whole article 🙂 )

  7. That link to a Belgian issue was embedded in the following sentence.

    Margrethe has made an extraordinary demand. She wants Apple to pay the Irish state an infarct-inducing sum in back taxes – between $8 and $16 billion, and I know that many of you will egg her on.

    So somewhere, someone has fucked up.

  8. Oops, ok, mentions Apple/Ireland in one sentence, with no numbers, saying the matter will be ruled on this year. Not a very helpful link there Boris.

  9. We all want Apple to pay more tax

    I don’t.

    All these tech companies make staggering sums from an avid British population.

    Yes, because they sell us stuff (or in Google’s case, give us stuff free at the point of use) that we want.

    and yet these companies pay quite derisory sums in tax to the UK Exchequer: derisory, that is, when you consider how much dosh they are earning from us all.

    Good. I hope they keep doing so.

    Because the UK Exchequer already gets its cut of anything I buy from Apple or Microsoft – a whopping 20% of the retail price of their latest fondleslab or what-have-you.

    That’s after nearly half my income’s already been nicked by the taxman through income tax and NI.

    And they want more?

    We want, need and deserve these companies somehow to pay more tax in the UK.

    Nah. It’d just get wasted on crap like HS2.

  10. Why do we “deserve” these companies to pay more tax? What the fuck have the UK government done for Apple that they haven’t already covered with VAT and business rates on Apple stores?

    I get pretty fucking mad about this stuff, because the bits of the economy that really don’t need land or other natural resources are the bits that we want to leave the fuck alone. They’re the businesses that can go anywhere in the world. It’s what Ireland have gotten right. Microsoft can put their Azure data centre anywhere in Europe with a decent supply of power, protection from criminals, reasonably skilled staff and a fat pipe onto the internet. That means most of Europe. Why the hell are they going to choose France with their gazillion employment laws and higher taxes over Ireland? And it’s not like it’s crowding out anything else. it’s outside the city, somewhere between Craggy Island and Ballykissangel.

    It’s why I’m drawn to LVT. You tax the stuff that can’t leave, where people depend on being here more heavily than the stuff that is optional.

  11. Doris Johnson is interested in just one thing, Doris Johnson. He will say today whatever he thinks is in Doris Johnson’s best interests, and tomorrow will say whatever he thinks is in Doris Johnson’s best interests even if it is the opposite of what he said today. That is all there is to Doris Johnson.

  12. “Why do we “deserve” these companies to pay more tax? What the fuck have the UK government done for Apple that they haven’t already covered with VAT and business rates on Apple stores?”

    Because there is such a thing as Corporation Tax in the UK. If small businesses have to pay it for trading in the UK, why shouldn’t big ones?

    If you don’t want them to pay for trading in the UK, then campaign for its removal.

    It doesn’t matter if a corp pays business rates, or that the employees pay Income Tax or that there’s VAT etc, CT exists.

  13. Arnald gets it spectacularly wrong again. UK businesses don’t pay corporation tax because they trade in the UK. They pay corporation tax in the UK because that is where they are domiciled.

  14. No thanks to Boris Johnson (or The Tele), I had to do my own research. The Apple thing seems to be the same as the Belgian one – an allegation that the State negotiated a special deal with a few companies, which is not allowed under EU rules, because otherwise butter lakes and wine mountains. That these deals involved allowing recalculation of underlying expenses to minimise reported profit not available to other companies. Odious, but a sovereign country is allowed to do stupid things.

    But Boris was banging on about the headline rate and tax competition, which is totally missing the point. The claim against Ireland (not against Apple, it is most definitely about ruling against Ireland that they should recoup the ‘illegal’ tax break) is calculated using the 12.5% rate. So this has nothing to do with national tax settings, and the low Irish rate is irrelevant.

    So based on what Boris is saying, he’s anti EU but in favour of higher taxes. That actually sounds about right. I just wish he would come out and say it.

  15. Because there is such a thing as Corporation Tax in the UK. If small businesses have to pay it for trading in the UK, why shouldn’t big ones?

    We’re going through this same discussion in Australia Arnald, with the same stupidity. Newspaper headlines quoting tax paid vs gross revenue, etc.

    Look at it this way, and the UK and Australia are in roughly the same circumstance. There is no manufacturing of Apple devices in Australia. The local subsidiary is basically a sales force, buying in product from overseas and selling on to the consumer at a markup. Minus running stores and paying sales staff, they make a small percentage profit on that markup. The gross value of the devices sold is obviously way larger than that. But if you taxed every importer on the gross value of their goods instead of the value added, they wouldn’t exist.

    So they are paying the relevant company tax. For the local operation revenue, minus their costs. Which includes importing the equipment in the first place.

  16. Arnald,

    “Because there is such a thing as Corporation Tax in the UK. If small businesses have to pay it for trading in the UK, why shouldn’t big ones?

    If you don’t want them to pay for trading in the UK, then campaign for its removal.”

    I’m not against completely removing it, but I am in favour of making taxes more about location values, which is generally about businesses that live more off the state and cannot move.

    To some extent, government even gets this. We pay film production tax breaks because we get that they can make Game of Thrones anywhere in Northern Europe with hills and coastline. They’re going to go where they get the best deal. So, we pay them a bit more which means that we raise more tax revenue from all the technical people working here. All that’s really being done there is adjusting tax towards LVT and in a crude and bureaucratic way (we don’t give the same incentives for shoe factories, small filmmakers can’t go through the paperwork).

  17. Fair enough, Crun. I was projecting the idea that companies ought to be taxed in the jurisdiction they do the trades in. But still, there is such a tax as corp tax and it should apply to any part of a business that has a UK domicile, like Google UK.

    London Weekend Television (I always think that when I see) Ltw

    One of the major reasons the likes of Google or any of them really, is that the UK subsid pays another subsid for the rights, is that not right? Conveniently it pays a substantial proportion of the revenue raised.

    I can’t believe for one minute that Apple shops in the UK are paying that much in import costs from Apple Elsewhere. It’s the same company. You can get a hell of a lot of phones per shipping container. etc etc

    Of course it all in the rules, and if someone doesn’t like it, they campaign against it. Which is why Worstall’s insistence on quoting Murphy’s campaigning is really just defending an unpatriotic position.

    Worstall, in his vague not-living-in-England way, his anti-Europe stance, whilst taking full advantage of those rules, is defending EU rules for US companies to screw the UK taxpayer. UKIP indeed. It’s a fraudulent position. Or deluded.

  18. “Arnald gets it spectacularly wrong again. UK businesses don’t pay corporation tax because they trade in the UK. They pay corporation tax in the UK because that is where they are domiciled.”

    No. Not so. If they trade in the UK through a permanent establishment they are chargeable to UK CT regardless of where they are resident ( what is domiciled?)

    S5 (2) CTA 2009

  19. Arnald, the problem is that you’re not distinguishing between trading *in* the UK, and trading *with* the UK; international tax law, on the other hand, does distinguish between the two.

    That is, you’re taking the fact that a person in the UK has bought something to mean that it was sold in the UK; but that’s not always the case with tangible goods, and it’s certainly not true with electronic services like Google’s.

    There is definitely an argument that it might be fairer to tax sales where the customer is; but it makes for a much more complicated set of rules and doesn’t do away with the possibility of avoidance. So all in all it seems better to stick with the system we have now – although perhaps with some strengthening of areas like the permanent establishment rules.

  20. “I can’t believe for one minute that Apple shops in the UK are paying that much in import costs from Apple Elsewhere. It’s the same company.”

    You had better believe they are paying the same price. Vodafone UK and Apple UK will be paying the same price to Apple Eire for an iPhone. It’ll be the most outrageous breach of the transfer pricing regs if they’re not. and seriously, the people who run Apple aren’t that stupid.

    ” You can get a hell of a lot of phones per shipping container. ”

    All air shipped. Value is too high to waste time having them lying about in a ship.

  21. Arnald, it also depends on whether Google UK is a cost centre or a profit centre. The Google UK offices are mainly focussed on engineering (Google Play, Search and Adsense) with a sales team. But does the UK operation generate enough revenue to cover the engineering costs? If it doesn’t make a profit it can’t pay CT.

  22. UK businesses pay corporation tax because they make a taxable profit. Corporations like the Guardian, with a business model which avoids profit and therefore pay little or no corporation tax, are therefore clearly scum sucking social parasites who provide no value whatsoever to hardworking British tax payers. They should be made to make a profit so they can be taxed. Right, Arnald?

  23. I can’t believe for one minute that Apple shops in the UK are paying that much in import costs from Apple Elsewhere. It’s the same company. You can get a hell of a lot of phones per shipping container. etc etc

    It’s not about shipping costs Arnald, which are such a miniscule amount of the total (whether by actual ship or by air) but the value of the product inside. And as I pointed out to you, the value added after receiving the goods is not that high.

    And as TW pointed out, if Apple UK were getting a better rate on imports than Vodaphone UK, thereby swelling the former’s profit so that they made a bigger UK profit to pay tax on, there would be hell to pay under transfer pricing rules.

    Go back and read what I said about Australia. The product is not being designed, developed, or manufactured here. So just why people feel that the consumer country deserves a share of the gross value escapes me. A share of the local operation’s profit margin, sure. But that is all you get.

  24. I can’t believe for one minute

    I’m sure that there are a lot of things you can’t believe. But for what is effectively a franchisee operation, no, they are not the same company. The international company will sell to you, what you get for it on the local market is your problem. They may be financing you, but your accounts are your own business. Been there years ago – I used to work for a subsidiary of SchneiderElectric in Australia. Although we belonged to them (share wise), we paid hard cash like anyone else for the hardware we were selling.

  25. Those having a big bash at Boris for being dome kind of closet SJW simply didn’t read this essay on the rule of Law and the directors’ ethical imperative. Better than just about anything I’ve ever read on it:

    “It is absurd to blame the company for “not paying their taxes”. You might as well blame a shark for eating seals. It is the nature of the beast; and not only is it the nature of the beast – it is the law. It is the fiduciary duty of their finance directors to minimise tax exposure. They have a legal obligation to their shareholders. Tax is not paid on the basis of what “feels right” either to public opinion or to politicians. It is not some eleemosynary contribution. It is not as if we are all in church, and watching beadily to make sure that Tim Cook puts his £50 note into the collection basket. Tax is paid, and must be paid, in accordance with the strict requirements of the system.”

  26. ” It is the fiduciary duty of their finance directors to minimise tax exposure”

    That’s bollocks.

    Companies Act 2006

    Duty to promote the success of the company

    Directors General Duties

    (1) A director of a company must act in the way he considers, in good faith, would be most likely to promote the success of the company for the benefit of its members as a whole, and in doing so have regard (amongst other matters) to—

    (a) the likely consequences of any decision in the long term,
    (b) the interests of the company’s employees,
    (c) the need to foster the company’s business relationships with suppliers, customers and others,
    (d) the impact of the company’s operations on the community and the environment,
    (e) the desirability of the company maintaining a reputation for high standards of business conduct, and
    (f) the need to act fairly as between members of the company

  27. Of course, whatever we could raise on service, support, training, and maintenance was entirely ours. Which is why car dealers are more interested in selling you the roadside assistance package than the actual car. Or for that matter, why petrol station owners are happier that you buy the two for one chocolate bars than a full tank of fuel.

  28. Arnald, in addition to what’s been said before, this: “Because there is such a thing as Corporation Tax in the UK.” is rather weak. Firstly, it’s too general. There Corporation Tax, and there’s all the treaties and loopholes that create exemptions to CT. A Govt that tolerates an existing loophole doesn’t ‘deserve’ the tax that would be due without it.

    But secondly, and more broadly, simply declaring a certain rate of CT doesn’t mean you deserve it. Companies will do business where the opportunities (supply chains, distribution routes, other infrastructure, labour with suitable skills) outweigh the costs (taxes, cost of that labour, etc, etc). And even then, they pick the most profitable one, so tax competition is a thing, even if it’s inconvenient to the Exchequer. As is skills-competition, wage-competition, blah blah blah.

    It’s cheaper/less work/more profitable (same thing, really) for these companies to work from Ireland, so Ireland gets their taxes. If we’d done better than Ireland, then we’d have a case for deserving their taxes.
    (Over and above what we get from VAT, business rates, tax from UK employment generated through the sales and stuff like app development, consumption of the income from that employment, productivity and personal benefits for those able to use those apps and all the others enabled by the platform, and so on and so forth…)

  29. Ian B,

    “Why do we want small filmmakers to run shoe factories?”

    The point is that we have schemes to encourage businesses to come here, but in specific industries. So, we might give film companies and software companies (and in the past, the likes of Honda) a tax break, but Dr Marten’s don’t get one, even though they can make DMs in all sorts of places.

    And the distinction with filmmaking is that someone making an ultra low budget film isn’t going to wade through all the bollocks bureaucracy to get a tax break (there’s a clause in there about “European culture” which I suspect is why there’s a pointless scene at Stonehenge in the 2nd Thor movie, and why Edge of Tomorrow ends at the Louvre).

  30. If they trade in the UK through a permanent establishment they are chargeable to UK CT regardless of where they are resident ( what is domiciled?)

    To be subject to UK taxation, a company has to be resident in the UK. It can get that through either being incorporated here (with some exceptions) or

    A company resides, for the purposes of Income Tax, where its real business is carried on … I regard that as the true rule; and the real business is carried on where the central management and control actually abides`

    Note that the residency test isn’t “having a permanent establishment” – that’s a feature of dual-taxation treaties – “selling stuff”, in any of its myriad permutations – you can be resident without manufacturing or selling a single item in the UK, or “Arnald and Ritchie want them to pay tax”.

    Or, frankly, Boris or Gideon want them to pay tax.

    However, we are talking not about a single company but about groups:

    It is particularly difficult to apply the `central management and control` test in the situation where a subsidiary company and its parent operate in different territories. In this situation, the parent will normally influence, to a greater or lesser extent, the actions of the subsidiary.

    It’s all here.

  31. He does, however, seem to be conflating two different things:

    “The Commission is plainly using the EU treaty articles on state aid to intervene in the tax jurisdiction of a member state when strictly speaking, it seems to me, they should butt right out…
    The Irish decided they wanted to go for an ultra-low corporation tax, at 12.5 per cent”

    Although State Aid and tax do sometimes overlap, they are not the same. State Aid is about anti-competitive arrangements with individual or classes of citizens; ‘sweetheart deals’. For example: is the TV licence fee State Aid? Setting low tax rates is not State Aid. This Danish lady is definitely looking at attacking State Aid…somewhere
    ..somehow.

  32. @ Arnald
    Companies pay tax in the jurisdictions where they make profits because they are taxed on profits.
    How hard is that to understand?

  33. Steve, you don’t pay 20% of retail price in tax.
    Its 16.67%.

    VAT is 20%, thats added tax. So 1/6th of the retail price.
    The retail price is 120% of what the seller wants.

  34. “Why do we want small filmmakers to run shoe factories?”

    Because much of what small filmmakers produce is cobblers?

  35. SE

    This is important, so we can and should go through it;

    “INTM120200 – Statement of Practice 1/90

    Residence has always been a material factor, for companies as well as individuals, in determining tax liability.”

    So a material factor rather than THE material factor.

    The true governing source material must be Statute:

    S5 (2) CTA 2009: “A non-UK resident company is within the charge to corporation tax only if it carries on a trade in the United Kingdom through a permanent establishment in the United Kingdom.”

    And subsection (3) provides for s19 to define what those profits are.

    So a non-resident company certainly can be subject to UK tax. And corporation tax is chargeable on single companies; always. So we definitely are talking about companies…and groups.

  36. Arnald

    Here is simply no way the directors’ duties can be regarded as being in any way incompatible with minimising tax liability. When a director minimises the CT he can always ALWAYS demonstrate it is in line with his fiduciary duties.

  37. @Ironman, agreed, though points have been raised elsewhere about entities like Starbucks having to be more sensitive to public mood than eg Google.

    So tax planning is never incompatible, but there may be tension between that and ‘business relationships with […] customers’

  38. NielsR

    Yes, agreed. And the company/group might desire certainty looking forward. Google have probably just made that very calculation.

    Dennis

    You win the thread.

  39. Re: Arnald

    “Fair enough, Crun. I was projecting the idea that companies ought to be taxed in the jurisdiction they do the trades in. ”

    So are you advocating withdrawing from the EU then?

  40. Peasant

    “You realize you’re arguing corporate taxation and directors’ fiduciary duties with a man who has to utilize payday lenders, right?”

    Yeah, and? Are you suggesting that knowledge is only the preserve of the puritan? Or indeed, the wealthy?

    Dick.

  41. Mr Rusty

    “When a director minimises the CT he can always ALWAYS demonstrate it is in line with his fiduciary duties”

    Nope, you’re wrong.

    “Google have probably just made that very calculation.”

    Oh, you know you are.

  42. Yeah, and? Are you suggesting that knowledge is only the preserve of the puritan? Or indeed, the wealthy?

    No, but if you inched within a mile of being marginally competent in your own personal financial affairs, your opinions on international corporate taxation and governance might ring a bit less hollow.

  43. “No, but if you inched within a mile of being marginally competent in your own personal financial affairs, your opinions on international corporate taxation and governance might ring a bit less hollow.”

    How?

    Iron-o

    No, I’m not. What’s your proof?

  44. For UK tax law,yes. Although an amiable discussion on Common Law jurisdictions with someone like you would be very enjoyable (a genuine complement), the law on tax residence and company Permanent estabkisents is as I’ve describe it.

  45. How?

    Lord, that is the $64,000 question, isn’t it.

    Learning the basics of taxation would be a start.

    I suppose I should stipulate that reading the blog of a moron like Richard Murphy doesn’t qualify as learning the basics of taxation…

  46. OMG Arnster. You’re not being clever and you’re not being funny. Why bother trying when you can just snuggle up with your own inadequacies and not trouble the world?

  47. I notice that online gambling offered by remote operators to UK punters is subject to a sort of point of consumption tax. You pay 15% of net profits from UK gamblers to the Exchequer and need a Remote Gambling Licence or whatever the technical term is.
    It’s all an attempt to increase tax revenues for HMG which are quite sufficient as they are imv – it’s the spending level which is an outlier in historic terms.
    However, I wonder if this sort of regulatory framework is unique to online gambling or could be applied to online advertising too.

  48. ““No, but if you inched within a mile of being marginally competent in your own personal financial affairs, your opinions on international corporate taxation and governance might ring a bit less hollow.”

    How?”

    I think Arnald is right here. His arguments are unlikely to ring less hollow, regardless.

  49. I’m now considering applying to the government for a grant to make a small film about a small shoe factory.

  50. Ian B,

    There’s Kinky Boots which is inspired by the true story of WJ Brooks in Earls Barton (and has shots of the village and Northampton). It’s rather sad in the way that it depicts the people from around there is some sort of Neanderthals.

  51. “Lord, that is the $64,000 question, isn’t it.”

    No it isn’t. You said that how I run my private life and what my opinions are, are somehow connected. Of course they’re not. My consumption should mean I’m a capitalist red in etc etc

    Do you have a credit card, Peasant?

    Imbecile.

  52. “OMG Arnster. You’re not being clever and you’re not being funny. Why bother trying when you can just snuggle up with your own inadequacies and not trouble the world?”

    Because someone has to counter your disturbing delusions, Bison. What do you stand for? Not caring about anything is not a viewpoint. It’s lazy.

  53. Arnie:
    Because someone has to counter your disturbing delusions, Bison.

    You can be confident that any disturbing delusions I might have could only be reinforced by such a master of nincompoopery.

    Not caring about anything is not a viewpoint. It’s lazy.
    My viewpoint is that you would be wiser to cloak your stupidity in silence.

  54. Hmmm. Is it possible to say “yes, corporation tax in 2002 was 5%, but now we going to declare that corporation tax in 2002 wa 20%, give us the extra 15%”

  55. Arnald –

    What I said was that it’s hard to take your opinions on taxation and finance seriously when you can’t manage to get from one paycheck to the next without the help of the friendly neighborhood Shylock.

    I have a credit card, a Volvo and a 2,300 sq ft house both completely paid for, an $800K investment portfolio and a $40K watch collection.

    What I don’t have is a payday lender.

  56. Credit is as credit does, Peasant.

    Can you lend me a tenner?

    “What I said was that it’s hard to take your opinions on taxation and finance seriously when you can’t manage to get from one paycheck to the next without the help of the friendly neighborhood Shylock.”

    *neighbourhood.

    The comment was nonsense then and it’s nonsense now.
    Being rich doesn’t give you anymore insight into any subject. Or more pertinently, as you’re bragging, it’ll make you blind to how normal people live.

    I’m guessing that’s the problem with everyone on here. It’s a form of mental illness.

  57. I’m in the USA, and we don’t spell certain words the way the wogs do. Keep that in mind next time you attempt to demonstrate intellectual superiority with regional spelling.

    Has nothing to do with being rich, because I’m not. What it has to do with demonstrating competence in some of the core competencies in the area of discussion.

    It’s hard to tell if your inability to comprehend is willful or God given.

    Plus, highlighting your inadequacies via compare and contrast is kind of fun.

  58. Well, duh, Peasant, do you folks in Murka spell things different?

    What’s a pay”check” anyway. It’s spelled cheque.

    You wouldn’t get very far in England.

    Can you lend me a tenner? You didn’t answer first time. I take checks.

    Yeah, you are rich, Peasant, but as I’ve explained, and you have not understood, it doesn’t demonstrate any particular “competence in some of the core competencies in the area of discussion.”

    Unless you think the world revolves around your ability to make your money attract more money. Which easy when you have it.

    Knowing about tax law, like AndrewC does, has nothing to do with owning a property.

    Arguing about wanting international tax law changes to stop companies taking the piss out of populations that don’t have your ready cash, has nothing to do with paying an adviser to place cash in “investments”. Even if you don’t pay an adviser, playing “investments” has nothing to do understanding how tax havens work.

    Your core competences are a product of luck. You were born into privilege. Of course I;m guessing at that, but the way you write stinks of condescension. A proper sociopath.

  59. Your core competences are a product of luck. You were born into privilege. Of course I;m guessing at that, but the way you write stinks of condescension.

    Luck? Privilege? Spoken like the resentful, envious loser you are.

    And of course my writing reeks of condescension towards you; I hold you in contempt… You’re a loser. And rather than attempt to address your deficiencies in a positive manner and rise above them, you make it your mission in life to drag others down to your level.

  60. Well, you weren’t born in central Africa, were you?

    I’m really not envious. I don’t want for anything, I’m surrounded by friends and family. I’m very lucky indeed. I don’t happen to be materialistic. I’ve waived any inheritance I would get so my kids can have a chance. The prevalence of greed is sucking the opportunities out from underneath the next generation.

    It’s more pity I feel, pity that you have to feel superior. It’s obviously something you strive for.

    You need to get out more and meet real people. Then you can decide how contemptuous to be.

  61. What a litany…

    As is the wont of losers, he first falls back on the assumption that he – and only those like him – can find happiness and comfort amongst family and friends. He imagines those more successful than he to be crouched at a counting house desk tallying coins and cursing the benevolence of others.

    Then, as is also the wont of losers, he imagines that those more successful than he don’t know “real” people, whomever they may actually be. (They are never actually named or defined, these “real” people that only he knows.) He assumes that success always involves a trade-off… One must sacrifice virtue, morals and/or authenticity to achieve.

    In fact, I dwell amongst real people. My clients are predominately immigrants (mostly Somali, but with a sprinkling of other countries). Say, 65%. Native born African-Americans make up another 10%. About 1 in 4 of my clients are white and Christian. My clients own and operate daycare centers, home health care companies, specialty markets, restaurants, clothing stores, roofing companies and landscaping businesses. I even have an evangelical Christian church and two mosques as clients. Amongst my closest friends I count a Vietnamese Buddhist. I buy my most of my watches from a Russian Jew. I’ve attended Muslim worship services at a mosque at the invitation of the mosque’s trustees. None of this should be construed as bragging… It is only statement of fact. And it is only being provided to demonstrate how hollow your Dickensian preconceptions of who I am and what I do really are.

    You’re a loser, Arnald. Do whatever you have to do to make it through your day, but don’t ask the rest of us to buy into your virtue signaling. OK?

  62. “As is the wont of losers, he first falls back on the assumption that he – and only those like him – can find happiness and comfort amongst family and friends”

    Didn’t say that. I said I don’t want for anything and I friends and family.

    About your experience of happy multiculturalism and immigrants, why aren’t you opposing the vagrants on other threads that think it anathema?

    None of what you’ve said dispels the fact that you like to feel superior. You bragged about your wealth. You weren’t asked to. I asked if you had a credit card. A yes would have done, but you did the counting house thing.

    “I buy most of my watches”. That counting house again.

    So what is it you do that you make so much money from your diverse clients? You listing their ethnicity and religion is also unnecessary. Are they poor, disenfranchised, alienated and without much hope? Obviously not. The real world is full of those. Really, who is virtue signalling here? My only signal was that I was waiving my inheritance for the good of my children.

    I still don’t see why you object to me saying your lucky. You’re a middle class American. It doesn’t get much luckier.

  63. You just can’t go a single post without stereotyping others, can you?

    Most of my Somali clients arrived in the USA desperately poor. For example, my best Somali client will pay tax on around $500K this year; he arrived in the USA 20 years ago with $40 to his name. My Russian watchmaker? 35 years ago he and his wife arrived with $1,000. My Vietnamese friend? He arrived with nothing… he was one of the Boat People who had managed to escape a “re-education” camp.

    I’ve spent a fair whack of time around a far more diverse and varied group of “real” people than you could imagine. They have been poor upon arrival, but they utilized their talents to make themselves into successful citizens. Oh, and they did so largely because the left the alienation and hopelessness to losers like you.

    The greatest irony of it all is this, Arnald: The vast majority of the poor and disenfranchised who arrive here end up despising the sort of patronizing, hand wringing, “concerned” progressive you are. They come here for the chance to be winners, not to consort with losers.

  64. By the way, what I am is a Certified Public Accountant in public practice. I sell them my services.

    And yes, I was born in the USA. That was indeed lucky. It was not, however, much of a determinant in my success. I know you can’t buy that, as it would undermine not only your world view but your own self esteem, but it is the truth.

  65. “They come here for the chance to be winners, not to consort with losers.”

    Like they do to the UK. I still don’t see you sticking up for the majority on other threads.

    Peasant, you are the one casting aspersions, I’m merely pointing out how you write.

    Did your immigrant clients ever need a credit facility? I mean, they weren’t your clients when they were poor, again I’m guessing.

    What is it you do again? I don’t have a linkedin account.

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