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Fergal Daly
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Not entirely surprising.
 
Here we go again... "TV manufacturers Samsung, LG, and Vizio build their TVs to pass US federal energy-use tests while allowing the TVs to consume much more energy when they operate outside of the narrow test parameters, a report from the Natural Resources Defense Council (NRDC) claims.

This week, the environmental group published the results of a study it did with third-party efficiency consulting firm Ecos Research (PDF). The study found that many of the TVs they tested used more than double the amount of energy listed on the yellow EnergyGuide label every time the TV was used under conditions not tested by the Department of Energy’s (DOE) energy-use test.

EnergyGuide labels also help determine whether a TV qualifies for an EnergyStar label, which indicates whether the TV is among the more energy-efficient in its group.

NRDC said it began testing Ultra-High Definition TVs for energy use in 2015 when it noticed “inexplicable, dramatic, and sustained drops in energy use in TVs from certain manufacturers, beginning within the first minute of the video test loop used in the DOE test method for new TV models.” The group decided to do additional research to figure out whether the DOE’s test resulted in an average energy draw number across settings or if TV manufacturers had narrowly tailored their energy-saving features to satisfy the narrowly drawn test conditions."
Like VW cheating with emissions, TV makers use test parameters to fudge results.
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There's an opportunity for Ireland here. We could let foreign manufacturers specify whatever energy ratings they want so long as they book their income in Ireland...
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Except Apple are one of the companies that pushed for DRM free music... and afaik iTunes now is entirely. The removal of headphone jacks is entirely about 1 more redundant space-consuming item that can be put to better use.
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A great write up.
 
Ireland ordered to recover €13 billion from Apple #longpost

In times like this, Irish news sources tend to circle the green wagons and pretend that the facts are nothing more than malicious gossip. So let's go to the primary sources.

http://europa.eu/rapid/press-release_IP-16-2923_en.htm
EU Commissioner for Competition press release: State aid: Ireland gave illegal tax benefits to Apple worth up to €13 billion

The first thing to notice is that it should be a lot more than €13 billion, but the inquiry is not allowed to order recovery from before 10 years before the investigation. The Irish Government is telling everyone that the 10-year limit is far too long.

The next thing is the narrow scope of the ruling. The Commissioner noted that Apple has been booking sales in Ireland which had nothing to do with Ireland. However, the ruling officially disregarded this, as "outside the remit of EU state aid control". The Commissioner also noted the shockingly low rate of tax that Ireland's deal allowed Apple to pay: "0.005% in 2014, which means less than 50 euros in tax for every million euro in profit". However, the ruling didn't take any issue with Ireland's ability to offer such tax bargains.

Instead, the ruling was focused on the special exemption from the "arm's length principle": the rule that corporations must be treated as equals before the law, able to make deals with one another as if they were independent businesses. The exemption allowed Apple to assign almost all of its operating profits to its IRNR, instead of to its sales branch which was supposedly earning the income. The sales office was liable for tax at 12.5%, but the "head office" had the deal allowing them to pay 0%. (Yes, zero.) The Commissioner ruled that because the allocation of profits didn't follow economic reality, it was fraudulent and allowed Apple to pay less tax than other companies.

A brief explanation of IRNRs is in order. An Irish-Registered Non-Resident company is a company which is registered in Ireland but not liable for paying tax in Ireland because its board meetings happen somewhere else. It's used as part of tax scams, because other countries' tax authorities regard the IRNR as paying tax in Ireland, and so IRNRs get to avoid being taxable anywhere. (Details: http://www.mondaq.com/ireland/x/5079/Incorporation+Of+Irish+NonResident+Companies)

The IRNR "loophole" was allegedly closed in 2015 when it hit mainstream headlines around the world, but the closure was a sham. The new rules have an exception for countries that Ireland has a tax treaty with. Malta and the UAE are such countries, and they also tolerate the taxable-in-country-of-board-meetings standard. For most affected companies, flying to Malta is more annoying than flying to the British Virgin Islands, but the benefit of the scam is enough to make it worth it. According to the Commission's ruling, Apple's IRNR's "activities consisted solely of occasional board meetings". (Details: http://www.natlawreview.com/article/death-double-irish-dutch-sandwich-not-so-fast-re-irish-incorporated-non-resident-com)

In an ingenious moment of Eristic scheming, the Commissioner suggested that other European countries (and the USA, and India) could fight over the €13 billion. "other countries, in the EU or elsewhere, can look at our investigation. If they conclude that Apple should have recorded its sales in those countries instead of Ireland, they could require Apple to pay more tax locally. That would reduce the amount to be paid back to Ireland. The amount to be paid back to Ireland would also be reduced if the two companies were required to pay larger amounts of money to their US parent company" (http://europa.eu/rapid/press-release_STATEMENT-16-2926_en.htm)

Considering that the basis of the Irish deal is that it allows the diversion of tax revenue away from other EU states, it would be very satisfying if it is clawed back by those other EU states. There's a certain moral hazard in the idea that Ireland could benefit from being caught cheating.

At the Guardian, +Simon Bowers suggested that the Commissioner's approach may backfire by provoking "powerful vested interests". (https://www.theguardian.com/business/blog/2016/aug/30/ireland-gets-an-apple-windfall-but-tackling-tax-avoidance-just-got-harder). The same outlet reported Apple's apparent confidence that the ruling will be reversed by the courts after a long legal battle; and, bizarrely, that the US treasury is apparently outraged by the ruling (https://www.theguardian.com/technology/2016/aug/30/order-back-taxes-overturned-apple-shareholders). It seems that Apple may be able to write off its EU tax against its US tax! There are many worms in this apple, it seems.

Naturally, the Irish Government is anxious that its credibility in offering sweetheart deals should be protected as far as possible. The state-owned broadcaster RTÉ reported (http://www.rte.ie/news/2016/0830/812819-apple-tax-ireland/) that the Apple companies "were controlled in the US where they held their board meetings" (the Commissioner's ruling was clear that the Apple IRNR "was not based in any country and did not have any employees or own premises"). RTÉ also interviewed Fianna Fáil's finance spokesperson who "said he did not see any economic rationale or legal basis for the commission basing its report on the assumption that up to 60% of Apple's global profits for a decade should have been solely taxed in Ireland." (That wasn't the basis.)

Sure enough, the US treasury is on the side of letting Apple get away with it, out of fear that Apple may find a way to write it off against US tax, or "a transfer of revenue from US taxpayers to the EU" as the White House press secretary put it (http://www.rte.ie/news/2016/0830/813036-white-house-apple/). Considering that the back taxes would be paid out of the colossal pile of money that Apple has intentionally not repatriated to the US, it's hard to see how this is a permissible write-off. I would suggest that the US refuse to compensate Apple' Inc. for the back taxes of Apple Sales International. After all, they're different companies, right? It's bizarre that the US would be on the side of Apple; this kind of tax dodging (or "legitimate multinational tax planning", if you prefer) harms the US taxpayer more than anyone else.

I'll finish with this quote from a director of the Tax Justice Network: “Apple illustrates the harm caused by tax wars between nation states. The sheer trickery of their tax arrangements renders their claims to corporate social responsibility risible, and the economic harm caused by these arrangements is also enormous. Despite their sitting on record levels of unspent cash reserves, Apple directors and their tax advisers have been cheating taxpayers around the world of billions of tax dollars. The world urgently needs a new framework for international cooperation to block countries like Ireland and Luxembourg from engaging in tax wars which harm democracy and cause untold damage to the quality of economic development.” (http://www.taxjustice.net/2016/08/30/apple/)
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A truly inspiring Olympics story.
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For anyone else wondering about the same thing as I was just now: despite Comedy Central logo there, it's an actual event.

https://en.wikipedia.org/wiki/Eric_Moussambani
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The hideous truth about Disney Princesses.
Imgur: The most awesome images on the Internet.
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The park was full of Pokemon Go players and I'm pretty sure that's what broke the Internet on my phone.

+Tatsuo Nomura​
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Nintendo created another miracle and made the whole world crazy again :+1:)
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Forensic evidence that puts people in prison doesn’t withstand scientific scrutiny. That’s a problem.
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The EU is finally preparing its new copyright law. It’s a historic chance to update outdated laws sto the new realities and opportunities of the digital revolution. But a leaked draft reveals nothing of the sort.

Instead, Commissioner Oettinger has let the publishing, film and music industries hijack the reform in an attempt to protect old business models from progress – at a tragic cost to freedom of creativity and expression on the internet, startups’ right to innovate and the cause of a Europe without digital borders.

[...]
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Now you have made me think it could have been so much fun ! See they moved the goalposts on the roaming charges at the last minute too 
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"Irish handmade Belgian chocolate". Dunnes Stores getting a little over-enthusiastic with the adjectives on their products.
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Made in Belgium by Irish hands?
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Just saw a guy poke an enormous painting at the Louvre with his finger. One of the big ones in the same room as the Mona Lisa. Why would you do that?
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Story for the grandkids
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Too big to jail.
 
Re: HSBC, the Intercept writes:
Treasury official Dennis Wood describes the AFMLS decision as an “internal recommendation to ask the bank [to] plead guilty.” It was a “bombshell,” Wood wrote, because of “the implications of a criminal plea,” and “the sheer amount of the proposed fines and forfeitures.”

But after British financial minister George Osborne complained to the Federal Reserve chairman and the Treasury Secretary that DOJ was unfairly targeting a British bank, senior Justice Department leadership reportedly sought to “better understand the collateral consequences of a conviction/plea before taking such a dramatic step.”


New evidence supports critique that Holder, for a combination of political, self-serving, and craven reasons, held his department back from prosecuting big banks.
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subs2srs allows you to create import files for Anki or other Spaced Repetition Systems (SRS) based on your favorite foreign language movies

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Nice shop. Hard to find. I posted a photo of the outside door.
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I got one of the best coffees I've ever had from the barrista here.
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Did was good but the owner getting people to dress up and climb on his camel is something special!
Public - 2 weeks ago
reviewed 2 weeks ago
I'm no burrtitologist so maybe they're supposed to be wet and goopy but I didn't enjoy mine.
Public - a month ago
reviewed a month ago
Haven't been here for a year. Kid's burrito was ok my taco shells were stale. Sums to have gone down hill a bit.
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reviewed a month ago