SAN FRANCISCO, December 22 morning news, the US Congress finally approved the Republican tax reform bill, which means that Apple will be 252.3 billion U.S. dollars in cash transferred back to the United States more cost-effective.
Apple will be able to take advantage of a one-time 'tax holiday' to pay only 15.5% of offshore cash instead of the 35% it previously paid. If Apple chooses to transfer all of its offshore cash back to the United States, it will pay a tax of 39.1 billion U.S. dollars , This assumption is not impractical because the company has previously made a provision of $ 36.3 billion for this purpose.
However, it is worth noting that, according to a Reuters report, Apple may be stymied by a provision set out in the tax reform act, which introduced a minimum tax rate of about 13% on U.S. companies' income from overseas patents, which May prevent Apple from continuing to use a method previously used to reduce tax payments.For Apple, the treatment of offshore patent revenues is important because in the past decades the transfer of these offshore profits It has always been the cornerstone of its tax practice.
In fact, Apple attributes most of its product value to patents and other intellectual property such as trademarks, and then distributes some of its intellectual property to affiliates located in low-tax countries to estimate the huge royalties on sales. , The royalties will flow back to low-tax countries such as the Netherlands, and the new rules mean that it will not matter which country Apple holds, as the company still has to pay taxes in the United States based on the income allocated to those patents.
To further prevent U.S. companies from distributing patents to offshore subsidiaries, the tax reform bill also reduces the U.S. income tax rate to 13.1%, implying that Apple will not allocate patents in the future To affiliates because it has almost become unprofitable to transfer it to tax haven.
The ideal goal of the U.S. Congress is that companies redistribute offshore patents to their home country without providing the relevant 'tax holiday.' In the final act, there is no explicit way for U.S. companies to remit overseas patents without tax.
Ed Kleinbard, a professor of tax law at the University of California, and former chief of staff of the Joint Committee on Taxation at the U.S. Congress, said the U.S. Congress has "screwed up." He believes that Congress may even do so Means that Apple's global tax bill will increase.
Earlier, Apple said it planned to transfer a portion of its offshore cash back to the United States, but did not disclose the exact amount, but a $ 36.3 billion provision meant the company plans to switch back to almost all cash.If Apple did Will make it capable of paying off all of the $ 97 billion of long-term debt.