A Ballsy But Genius Tax Avoidance Scheme of Apple

Apple Avoids Paying $17 Million In Taxes Every Day Through A Ballsy But Genius Tax Avoidance Scheme\
Walter Hickey | May 21, 2013, 4:16 PM

Apple CEO Tim Cook charmed the Senate today, testifying on the company’s tax avoidance practices.

The most interesting part of the story wasn’t on the Senate floor, however.

The report published by the Permanent Subcommittee on Investigations detailing Apple’s strategies is a great read on its own.

The report gives an inside look on Apple’s absolutely genius tax avoidance strategies.

Apple uses a variety of offshore structures and arrangements to shift billions of dollars from the United States to Ireland.

The U.S. corporate tax rate is 35%, while Apple said it has negotiated a special corporate tax rate in Ireland of less than 2%*.

(The 2% rate statement has proven controversial, see below for details)

Apple has found the secret to not paying taxes. You just avoid taxes by not declaring a tax residency for the company that oversees the entirety of your international income.

First, let’s look at Apple’s main offshore holding company:

Apple Operations International (AOI) is the company’s primary offshore holding company. It was registered in Cork, Ireland in 1980, and its purpose is to serve as a cash consolidator for most of Apple’s offshore affiliates. It receives dividends from those affiliates and makes contributions as needed.

• Apple owns 100% of AOI either directly or through controlled foreign corporations.
• AOI owns several subsidiaries, including Apple Operations Europe, Apple Distribution International, and Apple Singapore.
• AOI has no physical presence and has not had any employees for 33 years. It has 2 directors and 1 officer, all Apple Inc. brass. One is Irish, two live in California.
• 32 of 33 AOI board meetings were held in Cupertino rather than Cork.
• Shockingly, AOI doesn’t pay taxes. Anywhere. The holding company had a net income of $30 billion from 2009 to 2012, but has not declared tax residency in any jurisdiction.
• AOI’s income made up 30% of Apple’s total world profits from 2009- 2011.

A key quote from the report explains why AOI exists:

Apple explained that, although AOI has been incorporated in Ireland since 1980, it has not declared a tax residency in Ireland or any other country and so has not paid any corporate income tax to any national government in the past 5 years. Apple has exploited a difference between Irish and U.S. tax residency rules. Ireland uses a management and control test to determine tax residency, while the United States determines tax residency based upon the entity’s place of formation. Apple explained that, although AOI is incorporated in Ireland, it is not tax resident in Ireland, because AOI is neither managed nor controlled in Ireland. Apple also maintained that, because AOI was not incorporated in the United States, AOI is not a U.S. tax resident under U.S. tax law either.

Please take a moment to consider the genius of Apple Inc.

Apple Sales International (ASI) is a second Irish affiliate. It is the repository for all of Apple’s offshore intellectual property rights.

• ASI buys Apple’s finished products from contracted manufacturers in China — think Foxconn — and resells them at a major markup to other Apple affiliates in Europe, the Middle East, Africa, India and the Pacific.
• Although ASI is an Irish incorporated entity and the purchaser of the goods, only a small percentage of Apple’s manufactured products ever entered Ireland.
• Upon arrival, the products were resold by ASI to the Apple distribution affiliate that took ownership of the goods.
• Before 2012, ASI had no employees despite $38 billion in income over three years.
• Apple’s cost sharing arrangement facilitated the shift of $74 billion in worldwide profits away from the United States from 2009 to 2012.
• ASI’s parent company is Apple Operations Europe Inc. Together they own the intellectual property rights to Apple goods sold offshore.
• Like AOI, ASI claims to be a tax resident of nowhere. It’s not obligated to pay taxes to any nation.

*UPDATE: Earlier today an Irish minister disputed that Apple negotiated a tax rate less than two percent.

Here’s the section from the subcommittee report disputing that comment, directly from Phillip Bullock, Apple Inc.’s Tax Operation Head. The interview was conducted on May 15, 2013.

Apple told the Subcommittee that, for many years, Ireland has provided Apple affiliates with a special tax rate that is substantially below its already relatively low statutory rate of 12 percent. Apple told the Subcommittee that it had obtained this special rate through negotiations with the Irish government. According to Apple, for the last ten years, this special corporate income tax rate has been 2 percent or less:

“Since the early 1990’s, the Government of Ireland has calculated Apple’s taxable income in such a way as to produce an effective rate in the low single digits …. The rate has varied from year to year, but since 2003 has been 2% or less.”

Other information provided by Apple indicates that the Irish tax rate assessed on Apple affiliates has recently been substantially below 2%. For example, Apple told the Subcommittee that, for the three year period from 2009 to 2011, ASI paid an Irish corporate income tax rate that was consistently below far below 1% and, in 2011, was as low as five-hundreds of one percent (0.05%):

It seems as if any deal pertains to a calculation of taxable income that procures a sub-2% rate rather than a toggled rate in and of itself.

And from document PSI-Apple-02-004, provided by Apple to the Senate:

Since the early 1990’s, the Government of Ireland has calculated Apple’s taxable income in such a way as to produce an effective rate in the low single digits, and this is the primary factor that contributes to Apple’s rate. The rate has varied from year to year, but since 2003 has been 2% or less. This result is similar to incentives made available by many U.S. states and other countries to entice investment in their jurisdictions.

Read more: http://www.businessinsider.com/how-apple-reduces-what-it-pays-in-taxes-2013-5#ixzz2Tz9AwE72

Identity Seeking by Storytelling | Storyteller

Identity Seeking by Storytelling

Storyteller by Leslie Silko is a collection of work of different genres including photographs, poems, stories, interviews and mythology. It is “a unique showcase for Silko’s work” (Salyer). “Storyteller”, the short story bearing the same name with the book, is one of Silko’s finest work. It tells a story of a Native Amerian girl takes her revenge killing the white storeman who murdered her parents and becoming a storyteller in the end. However, as an outstanding piece of work of Native American literature, it is much more than a dark tale of revenge.

Multiple interpretations by critics have been aroused. Jim Ruppert reads the story as an identity seeking process of the main character who “loses the boundaries between objective reality and the story and between the present flow of the story and ideas of the past and future”. Nevertheless, Linda L. Danielson tries to interpret the story from a feminist point of view while extending narrative of the central character to the maintenance of cultural integrity “in opposition to the pressure of white culture”. She believes that Silko is “warning non-Indian readers to beware of the limits of their cultural system”. Similarly, Gregory Salyer also perceives the story highlighting “the bland uniformity of white culture”. Moreover, he argues that losing boundaries between ice and sky symbolizes “the loss of identity” of both individual and Native American culture as a whole. Emphasis of the story has been laid on the importance of “telling the difference”.

Given the cultural background and the text itself, “Storyteller” presents the reality of Native American culture struggling to maintain identity and independence as white culture encroaches. Silko leads readers to see the danger of uniformity of cultures and efforts Native Americans make to seek identity, to regain voice and to keep cultural integrity. This paper discusses how the theme is presented by examining the significance of storytelling in Native American culture, the symbolic meaning of ice, sky and sun and different reaction of characters.

The first thing needed in understanding the story deeply and comprehensively is reading the story in Native American cultural context. In Pueblo culture, storytelling is something predominant. It lies “at the heart of the Pueblo people” (Silko). Differing with definition in western culture, storytelling is “this constant process working on many different levels” (Silko). And the story must be told, as Silko says, “from the heart, unpremeditated and unrehearsed” (Silko). The telling “establishes permanence and maintains the culture” (Evans), the storyteller is “a highly revered member” who “has a unique relationship with the past” (Evans).

In the beginning of the story, the girl is only a listener who has no story to tell. Meanwhile, Grandma has the story about the death of the girl’s parents. The old man never quits telling his story of the bear. The girl asks questions and learns until she decides to make a story of her own, a story “about the red-haired Gussuck” (Silko p.30). She kills the storeman with tricks from the old man’s story and becomes a storyteller who does “not pause or hesitate” and “goes on with the story” and “never stops” (Silko p.62).

Just like the old man, the girl preserved her identity in continuously storytelling. Therefore, Native American culture is maintained in the same way. Refusing the excuse that the attorney makes up for her, the girl insists on telling the story in her own way, the way in which the story must be told and the way the Gussucks don’t understand and never will. It goes the same with the Native American culture. It must keep its integrity and independence resisting the assimilation and reformation of white culture. Only in this way, by telling the story as it is, Native American culture is able to survive.

The theme of cultural integrity and individual identity is best presented by the dominant image of merging of the ice and the sky and the sun. Silko warns people of the danger of cultural assimilation using this image in the very beginning of the story through the girl’s thought and words. “She told herself it wasn’t a good sign for the sky to be indistinguishable from the river ice, frozen solid and white against the earth” (Silko p.1). However, that’s the crisis state that Native American culture faces under the pressure of the white culture. Just like the sky “that were lost in the density of the pale ice” (Silko p.1), Native American culture loses itself in white culture’s infiltration. “The obliteration of contrast is the obliteration of boundaries, and boundaries are what form identity” (Salyer). Boundaries between ice and the sky are what have been lost in the story. They have been “swallowed by the freezing white” (Silko p.54). People are losing their language, traditions, lifestyle and environment that they live in. Everything that defines them and their culture is gradually replaced by new ones of white culture. Both the old man and the girl notice this. They know the threat of white culture and the disastrous result that the obliteration of cultural identity would bring. The image has been repeated several times in their words or through their eyes in the story. The storytellers are more like prophets speaking of their predictions. The old man claims that “it is approaching. As it comes, ice will push across the sky” (Silko p.21). The girl says “That was how the cold would come: when the boundaries were gone the polar ice would range across the land into the sky” (Silko p.44).

Individual is like the sun in the sky. The sun “wasn’t moving; it was frozen, caught in the middle of the sky” (Silko p.4). The sky is “solid as the river with ice which had trapped the sun” (Silko p.4). Native Americans have been lost their identity in the cultural assimilation as ice has already “pushed its way into the sky to seize the sun” (Silko p.48). They have been stripped off their language and abandoned their lifestyle, traditions and everything in their culture which they root in and which make them who they are. Nevertheless, they can never enter into white culture and has no say in the white world. They have been trapped by white culture.

However, the girl hasn’t given up seeking her identity and her own way to go. And she makes it by resisting influence of white culture and telling her story in her own way, a way in which Native American culture depends on for continuity. Her victory is also showed by the same image of the sun, the sun and ice in a contrast between the beginning and the end. At the end of the story, before she starts her story, the girl looks out the window and sees that “the sun has finally broken loose from the ice” (Silko p.60). The sun’s breakthrough and regaining of power symbolize the girl’s success in fighting for identity, integrity and freedom. Although it may be hard to make a great change with one person’s strength since the sun’s light is still “weak and pale” (Silko p.60), it is a start for finding its own place and getting Native American back to its track. The girl knows that white culture could and would be beaten as long as every native American beware of and keep their identity and integrity just like ice will finally “descend from the sky” (Silko p.59). The fate of individual and Native American culture has interacted.

The struggling for identity and integrity is also showed in different ways of storytelling of different people. Grandma keeps the story to herself until the girl asks. Her story is a story in which her role is to accept the result that the Gussuck have arranged. The story ends up with nothing conclusive after the storeman leaves, otherwise, she could tell the girl more (Silko p.39). Instead, she tells the story once and “never speaks of it again” (Silko p.39). The old man is the one from whom the girl learns the rules of storytelling. He keeps telling his story and tells it as it is. However, there’s no audience for his story. He warns people about the danger and how the end is approaching. No one understands or cares. Nonetheless, recognized or not, he possesses his identity and integrity in his storytelling and making his own ending.

The girl is more energetic and initiative in fighting for her own identity. She plans and takes control of her own story which is her own destiny. After the storeman dies as she intends, she insists on telling the story as it is. She refuses the reformation of the white attorney to the story even when telling the true story on the court may cost her life. She understands that “the story must be told as it is” (Silko p.59) just like culture must be kept its way without reconstruction and reformation by other culture. The three characters in the story have struggled to varying degree and ended with different destiny. However, as long as the story is told, the role in the story wouldn’t be dead and Native American culture will live.

All the analysis discussed above aims to clarify the theme of the story and how Silko manage to present rich meaning with a simple story. The significance of storytelling and storyteller in Native American culture lays the foundation for understanding this story. The author’s worries about cultural assimilation and the loss of self identity are best embodied in the image of the sun, ice and the sky throughout the story. Silko suggests her will for fighting and taking control of one’s own fate through different reactions of different characters. “Storyteller” is a wonderful story and a thought-provoking one. As Gregory Salyer puts it, it is a story “not simply entertainment or fantasy but invoke the realities” and “generates death as well as survival”.

Works Cited
Evans, Taylor Charlene. “Mother-Daughter Relationships as Epistemological Structures: Leslie Marmon Silko’s Almanac of the Dead and Storyteller”. Women of Color: Mother-Daughter Relationships in 20th-Century Literature. 1996. 87-172.
Salyer, Gregory. “Storyteller: Spider-Woman’s Web”. Leslie Marmon Silko. New York: Twayne, 1997. 58-84.
Silko, Leslie. “Storyteller”. Leslie Marmon Silko. New York: Twayne, 1997.
Ruppert, Jim. “Storytelling: The Fiction of Leslie Silko”. Leslie Marmon Silko. New York: Twayne, 1997.
Danielson, L. Linda. “A Feminist Reading of Storyteller”. Leslie Marmon Silko. New York: Twayne, 1997.

Companion Piece:

This paper is well organized in three parts with a brief introduction, body part and a sound conclusion. Three reasons have been offered: the importance of storytelling in Pueblo culture, the meaning behind the image of the sky, ice and he sun and different reactions of characters. Other scholar’s opinions and arguments have been acknowledged.

Text and Contexts: The Story Must Be Told | Storyteller

The Story Must Be Told

Writing Project: Text and Contexts
Essay Concerned: Storyteller

Leslie Marmon Silko, a contemporary writer and a Laguna, brings a new perception to language and literature, seeing the creation, history and time from the Pueblo perspective. Storyteller by Silko is a multigeneric work comprised of personal reminiscences and narratives, retellings of traditional Laguna stories and lovely maps of the fertile storytelling ground from which her art evolves and to which it is returned to. The book weaves itself into a spiderweb that brings together time, land, and experience, capturing the essence of life and language in a way that diverse audiences can appreciate. In Silko’s words, “the dimensions of the process” of storytelling is explained and both the structure and primary thematic concerns are established in the book.

The short story “Storyteller” could be recognized as Silko’s signature story in a highly condensed form with almost all the issues addressed in her other work. At its center is a young Eskimo girl, orphaned, living with a dying old man, the village storyteller who is victimized by Gussuck. She determines to avenge herself against the Gussuck storekeeper responsible for her parents’ death.

Leslie Marmon Silko’s works are widely studied by scholars. Edith Blicksilver examines Silko’s portrayal of Native American woman in her short stories and suggests that “Silko attempts to explore the conflict between traditionalism and modernity”. Jim Ruppert believes that in “Storyteller” the reality of the story and the individual’s identity are woven together into one story reality that patterns all others. Linda L. Danielson gives a feminist reading of “Storyteller”. She maintains that “the central character uses narrative to maintain the integrity of self and culture in opposition to the pressures of white culture”.

The “story” serves as several roles in “Storyteller” the title story and also in Storyteller the whole book. In her anthology, Silko establishes the significance of the “story”. As it is vividly portrayed in the title story “Storyteller”, story can be seen from three main perspectives on my behalf: story as the legacy; story as a way to seek identity; story as a weapon against assimilation.

First and foremost, story has been seen as the legacy. In “Storyteller”, story is the tie that bonds the old man and the girl, two generations of Native Americans, together. The old man is the village storyteller who tells story in an intensely beautiful precision and accomplishes it with his life. The story of a bear in winter that he keeps telling becomes the girl’s legacy. It is such a powerful version from which the girl learns when she decides to create a story of her own. Most importantly, besides the story itself, the way in which a story should be told has also been passed from generation to generation as a legacy. As the old man insists, the principle of storytelling says that “it will take a long time, but the story must be told. There must be no lies” (Silko p.42). It then becomes the principle of the girl who follows it strictly and even is willing to give up her freedom to defend it. At the end of the story, the attorney wants her to change her story to tell the court that “it was an accident” (Silko p.59), but the girl refuses, even though to follow his advice would mean freedom. She chooses to carry the legacy of the old storyteller and becomes a storyteller herself.

Besides her bonds with the old man, the girl also shares a grandmother-granddaughter pairing relationship with her grandmother. According to Leslie Marmon Silko, Native American woman has been “the tie that binds her and people together, transmitting her culture through story from generation to generation” (Charlene). In “Storyteller”, the girl receives another precious legacy from her grandmother, which is the story of her parents. Being acknowledged of her parents’ death, the girl enters more deeply into her family and her culture.

Another important perspective that “Storyteller” discusses is that storytelling can be seen as a way to seek identity, not only the identity of individual one but also the whole community. The creation story plays a significant role in Native American culture. Silko has pointed out that “the origin story functions basically as a maker of our identity—with the story we know who we are. Then from the idea of one’s identity as a tribal person, we can move into clan identity”.

The title story “Storyteller” could be seen as a story of identity-seeking journey. Important characters in “Storyteller” all have their stories. The girl’s grandmother has the story of the girl’s parents. The old man keeps telling the story of the bear. Those stories establish their role in family, in community and in humanity.

In the beginning, “the nameless girl is ignorant of her identity” (Ruppert). She has no story of her own to tell. She wonders about the world which confuses her with all kinds of conflicts and finds it hard to attain a place. She tries school but only has a harsh time when Gussucks tries to change and reform her in their way with their lifestyle and language. When her grandmother dies, the girl chooses to live with the old storyteller, which allows her defining herself in her own way. Grandma’s story about her parents’ death marks the beginning of her identity seeking since she decides to plan her own story from that moment. She listens very carefully to the old man’s story and uses tricks that she learns from it in creating her own story. She finds her place in the world as a daughter, a granddaughter, a Native American, a rebel and a creature of nature in her story-creating. And finally, she completes her identity journey by becoming a storyteller who insists telling the story “as it is” (Silko p.59).
Nevertheless, Pueblo community achieves its identity from story and storytelling. In the story, characters are bonded together by stories and they confirm their identity as a Native American seeing the world from the Pueblo perspective by storytelling. That’s how clan identity is confirmed.
Last but not the least, story can be seen as a weapon against “assimilation” which is not only refers to individualities but also the cultures.

Assimilation has embodied in the image of merging of the sky and ice. It is repeated several times throughout the story while playing a significant role in story developing. Silko suggests the theme concerning cultural assimilation and warns of the danger of it in the very beginning of the story by saying that “it wasn’t a good sign for the sky to be indistinguishable from the river ice, frozen solid and white against the earth” (Silko p.1). However, it seems that the old storyteller is the only one who notices it while other citizens have bent to it. He passes the information to the girl telling her that “ice will push across the sky” (Silko p.21).

The powerful weapon against it is storytelling. Silko emphasizes that the boundaries between the sky and ice are losing. Boundaries, according to Salyer, “are what form identity”. Keeping identity, as well as being distinguishable, is essential to keep a culture from losing itself in cultural assimilation.

However, it has been already discussed above that story is significant for an individual and a community to seek identity. Unlike other indifferent and confusing village people who have lost themselves in assimilation, grandma, the old man and the girl follow the Pueblo traditions, lifestyle and speak native language. Those are what define them and make them who they are. And most importantly, they find their way to defend these valuable things with storytelling. The old man’s story which are told with passion in a traditional way is a typical one of how Pueblo people get along with other creatures showing the Pueblo perspective of seeing and dealing with the nature. The story that grandma tells is an accusation of the wrongdoings and damage that the white bring. The girl tells her story of resisting assimilation and oppression of White culture.

Red that witnesses the story of her parents’ death has been used by the girl to mark the boundaries. “The east bank of the river was lost in the sky; the boundaries had been swallowed by the freezing white. And then, in the distance, she saw something red, and suddenly it was as she had remembered it all those years” (Silko 54). The victory of storytelling against assimilation has also been shown in the image of the sky and ice. When the girl insists telling the story in her own way after killing the storeman, she knows that “the ice descending from the sky” (Silko p.59). By telling the stories and telling it the way it should be, the Pueblo culture is able to survive.

“Storyteller” is a dark tale of racism and revenge but also of the integrity of stories and their tellers. It vividly and clearly presents the very essence of Silko’s works. Silko expresses, with grace and power through her melding of oral tradition and the written words in Storyteller, the sense of life being lived, of timeless and ongoing, changing and evolving, contradictory and continuous. Story, as the one of most important elements in her works and also in the tradition of Pueblo culture, can be seen as legacy that maintain the essence of traditional culture; as a way of seeking identity from being aware of the past and pursuing their present; as a weapon against assimilation of others and other cultures.

Works Cited
Blicksilver, Edith. “Traditionalism vs. Modernity: Leslie Silko on American Indian Woman”. Southwest Review 64.2 (1979): 149-160
Salyer, Gregory. “Storyteller: Spider-Woman’s Web”. Leslie Marmon Silko. New York: Twayne, 1997. 58-84.
Silko, Leslie. “Storyteller”. Leslie Marmon Silko. New York: Twayne, 1997.
Ruppert, Jim. “Storytelling: The Fiction of Leslie Silko”. Leslie Marmon Silko. New York: Twayne, 1997.
Danielson, L. Linda. “A Feminist Reading of Storyteller”. Leslie Marmon Silko. New York: Twayne, 1997.

Reflective Companion Piece:

“Storyteller” is not an easy short story for reading. In order to understand it, information about the author and Native American culture and other research are needed. This paper is based on a close examination and full acknowledgment of cultural background. It also introduces other scholars’ opinions and interpretations with which the view of its own has been better demonstrated.

The paper is well-organized with an introduction part of the book and the short story, a brief literature review, self presentation and argumentation and conclusion. It makes a very clear thesis statement with simple words. Each view then is explained deliberately with detailed analysis of the text. It provides a comprehensive interpretation with the short story.