...APPLE TAX AVOIDANCE SCHEME DOUBLE NON-TAXATION April 2015 1 Apple International Structure Source: New York Times 2 Taxation Principles RESIDENCE: • Incorporation • Place of Management -> Case of Ireland SOURCE: • Source jurisdiction is generally expected to have priority, but the concept of source is generally poorly developed in domestic tax legislation • Notion of permanent establishment, head office and transfer pricing rules 3 Double Irish Arrangement • The Double Irish Arrangement is a tax avoidance strategy that some multinational corporations use to shift income from a higher-tax country to a lower-tax country. • It is called Double Irish because it requires two Irish companies to complete the structure. One of these companies is tax resident in a tax haven 4 Apple Operations International (AOI) • AOI, the company's primary offshore holding company, made up 30% of Apple's total world profits. • Residence: Irish and U.S. tax residency rules: • Ireland uses a management and control test to determine tax residency. • United States determines tax residency based upon the entity’s place of formation. • AOI is incorporated in Ireland, it is not tax resident in Ireland, because AOI is neither managed nor controlled in Ireland. Because AOI was not incorporated in the United States, AOI is not a U.S. tax resident under U.S. tax law either. 5 Apple Sales International (ASI) (1) • The second...
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...a. Tax avoidance in Germany (Siddhart Medhi) A number of schemes exist in the tax system, which enables corporations to avoid taxes and some of these loopholes are perfectly legal. In 2009 the German newspaper, Der Spiegel, reported a scheme referred to as the Malta Loophole. It is quite simple and has been used by multinational corporations such as Lufthansa and Puma. It works by setting up a subsidiary in Malta and thus paying taxes to the Maltese state. The tax rate in Malta is 35% and is thus higher than in Germany, however, the shareholders can apply for a refund for most of the amount. The reason for this is that if profits are being distributed as dividends then the tax rate is only 5%. The scheme works in the following way: if the profit of the subsidiary is 100 million then 35 million is paid to the Maltese state where after the shareholders can get a refund of 30 million and return it to the German parent company. Returning the money from the shareholders is due to the German tax system 95% tax exempt. The effective tax rate is thus cut to merely 6.42% Another example of tax avoidance is when Volkswagen took full control of Porsche in 2012. Volkswagen at the time already owned 49,9% of the shares in Porsche and was interested in buying the remaining 51.1% in order to have full control and gain synergy effects worth €700 million a year (Bryant, 2012). The price of this was €4,5 billion, which would have to be taxed by €1,5 billion. However, they found a way around...
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...Five Conflict Management Styles Here are the five conflict management styles according to Thomas, K.W., and R.H. Kilmann: Accommodating – This is when you cooperate to a high-degree, and it may be at your own expense, and actually work against your own goals, objectives, and desired outcomes. This approach is effective when the other party is the expert or has a better solution. It can also be effective for preserving future relations with the other party. 1. Avoiding - This is when you simply avoid the issue. You aren’t helping the other party reach their goals, and you aren’t assertively pursuing your own. This works when the issue is trivial or when you have no chance of winning. It can also be effective when the issue would be very costly. It’s also very effective when the atmosphere is emotionally charged and you need to create some space. Sometimes issues will resolve themselves, but “hope is not a strategy”, and, in general, avoiding is not a good long term strategy. 2. Collaborating – This is where you partner or pair up with the other party to achieve both of your goals. This is how you break free of the “win-lose” paradigm and seek the “win-win.” This can be effective for complex scenarios where you need to find a novel solution. This can also mean re-framing the challenge to create a bigger space and room for everybody’s ideas. The downside is that it requires a high-degree of trust and reaching a consensus can require a lot of time and effort...
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...Personal Thinking Styles Pursuant to my Life Styles Inventory (LSI): Self-description results my primary personal thinking style is “Avoidance” with a percentile score of 55% and my back-up thinking style is “Conventional” with a percentile score of 50%. As I reviewed my circumplex I became rather disturbed as I tried to understand the “Avoidance” scale. The LSI description of Avoidance states that the this thinking style is defined by tendencies of denying responsibility and your behavior, feelings of guilt and an obsession of your own concerns. I have trouble relating to these characteristics as I hardly stray from responsibility if it’s warranted or of having guilty feelings and am definitely not obsessive over my own concerns. In fact, I always own up to my responsibilities and/or any mess ups either at work or at home. I have not been in a role of a manager yet have supervised a number of interns and I have never been threatened by or with any responsibilities pushed upon me. In fact, I almost always took same on with confidence and a sense of dedication. I do agree with the assessment that at times I may not give myself full credit where I completely deserve it; I have attributed this more to humility than to insecurity. Although I am not hard on myself for mistakes and misjudgments I do, however, tend to dwell on things far longer than necessary. For example, if during a presentation I stumbled in answering a question I would live with the embarrassment of same...
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...Traffic Alert and Collision Avoidance System and the Human Element Terry D. Gilfillan Embry-Riddle Aeronautical University Abstract This paper describes the history of the Traffic Alert and Collision Avoidance System (TCAS). It will discuss the types or categories of and the operation of the system of TCAS, to include the components involved, how the system interacts with other aircraft that are equipped with TCAS, and the related warnings and/or notifications of the system. Also discussed is the human element related to the operation and interaction of TCAS. These human elements include the human senses and situational awareness. Traffic Alert and Collision Avoidance System and the Human Element Two planes collide in the skies somewhere over the Grand Canyon on 30 June 1956. Because of this collision and many others, the aviation industry came to the realization that some type of system or process had to be created to help with the prevention of these collisions. Several companies began the design of collision avoidance systems, however it wasn’t easy, as they had to overcome two specific obstacles. First, the air carrier would have to install or outfit their fleets with the new hardware for the system and that would prove to be very expensive. The second obstacle; there would still be a lot of planning and development to do before TCAS would be up and running efficiently. That being said, TCAS was still in development on 31 August 1986 when a midair collision...
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...Life Style Inventory Results Management 591 Leadership and Organizational Behavior Anne Hallcom September 16, 2012 The LSI, life styles inventory, measures twelve specific patterns of thinking that are broken down into three categories: constructive, passive/defensive, and aggressive/defensive. Constructive styles reflect self- thinking to receive your own satisfaction, develop relationships to work with people, and task completion. Passive/defensive styles reflect self- protecting thinking to ensure security needs with people. Aggressive/defensive styles reflect self-promoting thinking to maintain position through security needs by task-related activities. After taking the LSI survey my primary and secondary styles of thinking fall under aggressive/defensive thinking. My limiting style of thinking falls under passive/defensive thinking. My primary thinking style, power, measures your self-worth to a degree that we can control and dominate others. Power thinkers lack confidence in others and try to establish their feelings of self-importance. Power thinkers are characterized to be aggressive and to have a rigid way of thinking. Power thinkers have a high need for control, power, prestige, and status. Power thinkers dictate the actions of others and they are threatened by undermined authority. Consequently, the qualities I found to be true about me regarding power is that I have a lot of aggression, lack confidence in others, and I have a high need of control and influence. At...
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...1.0 introduction The Thomas Kilmann Model is simple tool that provides practice scenario of particular methodologies to managing conflict viably. The exploration upheld TKI offers a commonsense approach to launch safe and nonemotional discourse to resolve conflict. That is the reason its perfect for utilization in such a variety of diverse situations. It can additionally enhance organizational profit by helping individuals pick up knowledge into their own particular and others' conduct which thus helps them settle on better decisions about conclusions. The TKI is directed in simple to-utilize online and self-scorable configurations. Conflict is an inescapable part of human relationships. Where responsibility to mission and extended periods with negligible assets converge, not-for-profit work environments might be overflowing with conflict trades. Conflict can go out from administering varying viewpoints and clearly inconsistent concerns. Assuming that we can acknowledge it as a regular part of our zealous scene, it might be simpler to work with than in the event that we need (or wish!) conflict to never resurface. 2.0 Introduction of Thomas Kilmann Models. The Thomas-Kilmann Conflict Mode Instrument is intended to evaluate an individual conduct and behavior in certain scenarios. "Conflict Situations" are the scenarios in which the concerns of two individuals seem, by all accounts, to be incongruent. Conflict is a social culture...
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...GM591: Leadership and Organizational Behavior LIFE STYLES INVENTORY When proceeding with this life style survey, I was convinced that my “primary” style and/or my “back up” style will be far transparent from being Conventional and Oppositional. Moreover, in reviewing more in depth towards the final results, some of the outcomes are not exactly what I was expecting. In areas I thought should have resulted in a superlative score it barely met expectation in my scheme of things. Conventional-oriented has been revealed to be my “primary” style as the scoring was in the 98 percentile. I am by far not a manager that sees rules as more important than ideas. In fact, I do have a conservative behavior; however, it does not keep me away from trying new things. When working in a job I have always set goals and guidelines to be successful at my job skill. It has always persevered because I either was promoted at a rapid rate or acknowledgement went to me for an outstanding job. When working on a new job task that has been thrown my way, I get exhilarated from the new at all times. This describes more of an achievement-oriented “primary result” and what I was expecting at the end. At work, I am not seen as manager that will do things “by the book.” However, I am typically concerned with doing what is expected, but I am seeing as a manager that has high abilities to motivate subordinates to set goals and...
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...Journal 2 When it comes to me and negotiation I fall under the category of avoidance. I will say that if there is a way to avoid a major conflict or future conflict I usually take the steps to do that. There are also many times when I personally find things not worthy of a major discussion. I would rather take care of things that are going to have a major impact rather than little complications that pop up here and there. Time management is something that I focus on, so there are times where I do avoid issues that could be solved and they end up turning into a bigger situation then they needed to be. When I thought about this I realized that being an avoider could actually be a big disadvantage. When I continually avoid all the smaller issues that are occurring they have the potential to turn into one huge issue. That large issue will probably end up taking a lot more time to resolve, and could result in the relationships that I have being hurt. If you are not willing to sit down and have discussions with your counterparts or even people on your side, you risk the chance of them not wanting to work with you at all. Once that happens it will be a lot harder to get a deal done when the time comes for a negotiation of some sort. Another disadvantage of being an avoider is the fact that if you are constantly avoiding situations that could be resolved with a little bit of negotiation nothing will ever get done or get changed. When you look at some of the traits of an...
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...Frankfurt School of Finance & Management Intercultural Management Uncertainty Avoidance By Arina Hadlich Alok Mani Tripathi Program: Master of International Business June, 2013 Contents Essence of Uncertainty Avoidance 3 Uncertainty Avoidance Index 3 Uncertainty Avoidance and Anxiety 4 Uncertainty Avoidance According to Occupation, Gender and Age 5 Uncertainty Avoidance in the Family 5 Uncertainty Avoidance Health and (Un)happiness 6 Uncertainty Avoidance at School 6 Uncertainty Avoidance in Shopping 6 Sources 7 Introduction We live in the age of rapid globalization. New technology has shrunk the size of the world. The world has become a small state with a few big cities, few towns and villages. The cities are markets for the products form towns and villages, and vice versa. This shrinking in size has brought people from different cultures and backgrounds to work together under the same umbrella. Wherever you go, even the smallest of the company has people from different cultural backgrounds. This mixing of so many cultures at workplace has come up to be challenge for the modern organizations. The modern managers or leaders find it difficult to make a decision for their team, which comprises of people from different cultural and educational backgrounds. There is always a problem of synchronization within the team, which is faced by a modern leader. Since different statements are perceived differently in different cultures, the problem of miscommunication...
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...Error Avoidance in Post Modern/Complex Adaptive Systems Lindsey Webster MHA601: Principles of Health Care Administration Tricia Devin Monday, December 2, 2013 Error Avoidance in Post Modern/Complex Adaptive Systems Complex adaptive systems (CASs) are omnipresent. “Examples of complex adaptive systems include the electric power grid, telecommunications networks, the Internet, biological systems, ecological systems, social groups, and even human society itself” (Decision and Information Sciences Division, N/D). “Complex” implies diversity – a wide variety of elements. “Adaptive” suggests the capacity to alter or change – the ability to learn from experience. A “system” is a set of connected or interdependent things. In a CAS, the “things” are independent agents. An agent may be a person, a molecule, a species or an organization, among many others. These agents act based on local or surrounding knowledge and conditions. A central body, master neuron, or CEO does not control the agent’s individual moves. A CAS has a densely connected web of interacting agents, each operating from its own schema or local knowledge. This paper discusses Complex Adaptive Systems in a holistic context. It aims to analyze the occurrence of errors and how these errors can be avoided by successful error avoidance in post modem or complex adaptive systems. Why do errors happen? The common initial reaction is to find and blame an error on someone. However, even apparently...
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...K-6 School Administration Entry In our current society we have seen an increase of violence at current education centers throughout the United States. School facilities are now easy targets for unstable individuals or groups of people who prey on easy targets for national and world recognition through media sources. One of the projects that I will be addressing with bond monies this year is making a K-6 School Administration entrance secure. Fifteen years ago when threats to society were at a minimal, the marketing and architectural designs were to build entrances that were community friendly. This issue is that the entry area is open with no control points that prevent entry and security to the staff and children. Risk Avoidance Altogether * Entrance to the school will receive CCTV (Closed Circuit Television and Video) monitoring 24 hours per day of entry area and internal lobby. * Badged entry into the front lobby after hours. * Design of new lobby entry that can trap all visitors into a holding point. * Bathroom access from lobby for public use. * Installation of Raptor Visitor management Software that will provide instant sex offender and background checks to prevent unwanted visitors out while tracking those they allow in. * Security system for entrance to prevent unwanted intruders after hours * Motion sensors for lighting that will activate after hours so responding officials can visually see the intruder. * Secure entrance into the...
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...Error Avoidance Beth Burhans MHA 601 Principles of Health Care Administration Dr. Tricia Devin September 16, 2013 Error Avoidance There are errors in all ways of life and in all industries and workplaces. Some errors are unavoidable, while many errors are avoidable whether through planning and strategy or better training practices. In the healthcare field, errors can be very simple and not have a big impact, or they could be so significant that they could result in loss of life. As an administrator of a healthcare facility, it is imperative that the procedures, training, and regulations are updated and followed throughout every level of the facility from the maintenance crew, non-clinical staff, clinical staff and nurses and on up to the doctors themselves. The first error that could be avoided involves the operation of machinery and the employee attempting to create work around procedures on their own to enhance their own production (Johnson, 2009, p. 80). Although this sounds like a positive initiative on the part of the employee, this could prove dangerous if the proper safe guards are not being followed concerning the machinery involved. When shortcuts are taken, there is usually a consequence that will have to be paid, whether it shows up immediately or somewhere down the road. The next error that could be avoided involves “putting all employees through the same orientation program regardless of cultural interpretations of organizational hierarchies” (Johnson...
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...IoD Big Picture Summer 2013 Tax avoidance: remedies and collateral damage SNAPSHOT • The term ‘tax avoidance’ needs to be carefully defined and is not the same as ‘tax abuse’ or ‘tax evasion’. This article considers where avoidance becomes abuse and, in particular, the advantages and disadvantages of some measures to control it. Tax avoidance: remedies and collateral damage Richard Baron, former Head of Taxation at the IoD, and Stephen Herring, his successor, consider the proper use of the term ‘tax avoidance’, where avoidance becomes abuse, and the pros and cons of some measures to control it. • The basics of UK tax law are simple, but difficulties arise from complex transactions that require specific rules – which in turn create opportunities for aggressive tax avoidance and abuse. ax avoidance has rarely been out of the news over the past two years, although the term has also rarely been properly defined and has often been muddled both with tax abuse and, even more incorrectly, tax evasion. Commentary has focused on two separate assertions that tax avoidance is taking place. Firstly, claims that some multinational groups of companies, generally US-owned, have undertaken planning which might involve recognising profits in one country rather than another that has higher corporation tax rates. Secondly, introducing planning arrangements to secure better treatments of financing costs, intellectual property rights and undistributed profits by locating business...
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...Shui Fabrics is a 50-50 joint venture between U.S textile manufacture and Chinese company launched by Rocky River, they produce dye and coat fabrics for sale both Chinese and international sportswear manufacture. Ray Betzell is an American manager and Chui Wai is the Chinese the manager of Shui Fabrics. A performance oriented society is a society with a high performance orientation that places high emphasize on performance and rewards people for performance improvements and excellence. On contrary a low performance oriented society pays less emphasis to the performance and more importance to loyalty, belonging and background. Ray Betzell, the American general manager was on a call with the president of Rocky River, Paul Danvers. Based on their conversation, Paul Danvers was very disappointed on the 5 percent annual return on the investment, instead he had much higher expectation around 20 percent annual return on investment. Whereas, Chui Wai is pleased with the way the business is running and according to him Shui was generating the right amount of profit at 5 percent annual return on investment. This shows that the American boss, Paul Denver is more a high performance oriented person than Chui Wai. The second dimension is assertiveness. A high value on assertiveness means a society encourages toughness, assertiveness and competitiveness. On the other hand low assertiveness means people value tenderness and concerns for others over being competitive. To add to this, the...
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