Trains.com

CP & CN tax inversion?

2629 views
13 replies
1 rating 2 rating 3 rating 4 rating 5 rating
  • Member since
    December 2007
  • From: Georgia USA SW of Atlanta
  • 11,919 posts
CP & CN tax inversion?
Posted by blue streak 1 on Tuesday, August 26, 2014 7:36 PM

The talk of Burger King moving headquarters to Canada brings up a question.  What tax benefits and how are they applicable to CP & CN ?  It is interesting that a company can move profits to Canada then loan the funds back to US subsidiaries.  Other items as well ?

  • Member since
    February 2003
  • From: Guelph, Ontario
  • 4,819 posts
Posted by Ulrich on Tuesday, August 26, 2014 8:59 PM

Our corporate tax rates (combined federal, provincial, municipal) are about 15% lower than yours are...so one can't blame Burger King. After all, globalization is great when businesses need cheap labor, so why can't they also shop around for lower taxes?  To all those folks who say Burger King is "un-American"  I ask, is exporting jobs to low wage countries with lax environmental laws the Amercian way? I think not. One can't have it both ways.

About CP and CN, they have a large presence in both countries  and their tax obligations are very complex. This is why they have tax lawyers and accountants on the payroll.  

  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Tuesday, August 26, 2014 10:24 PM

Ulrich

Our corporate tax rates (combined federal, provincial, municipal) are about 15% lower than yours are...so one can't blame Burger King. After all, globalization is great when businesses need cheap labor, so why can't they also shop around for lower taxes?  To all those folks who say Burger King is "un-American"  I ask, is exporting jobs to low wage countries with lax environmental laws the Amercian way? I think not. One can't have it both ways.

About CP and CN, they have a large presence in both countries  and their tax obligations are very complex. This is why they have tax lawyers and accountants on the payroll.  

If you have to move countries to lower your taxes - fire your tax department, they are incompetent in being able to tap into the corporate welfare in the tax structure.

Never too old to have a happy childhood!

              

  • Member since
    February 2003
  • From: Guelph, Ontario
  • 4,819 posts
Posted by Ulrich on Tuesday, August 26, 2014 10:51 PM
The news media, as usual, have oversimplified the BK Tim Horton transaction. There's a lot more to it than moving BK to Canada to save taxes. If it were all about taxes then GM and General Electric (and most other American companies) would be here too, and I'm pretty sure their managers are at least as capable as the people who run Burger King. The tax angle is being exploited by some for political advantage and the news media eat it up.
  • Member since
    August 2008
  • From: Calgary AB. Canada
  • 2,298 posts
Posted by AgentKid on Wednesday, August 27, 2014 3:28 PM

Ulrich
If it were all about taxes then GM and General Electric (and most other American companies) would be here too, and I'm pretty sure their managers are at least as capable as the people who run Burger King. The tax angle is being exploited by some for political advantage and the news media eat it up.

Thanks for that slap upside my head. I too, was being sucked into the media hype on this issue. I will now resume my Rochelle webcam viewing.

Bruce

So shovel the coal, let this rattler roll.

"A Train is a Place Going Somewhere"  CP Rail Public Timetable

"O. S. Irricana"

. . . __ . ______

  • Member since
    October 2006
  • From: Allentown, PA
  • 9,810 posts
Posted by Paul_D_North_Jr on Wednesday, August 27, 2014 8:39 PM

I'm certainly no expert - or even moderately well-informed - but in theory (and "in a perfect world" with a 'clean slate' without past financial and legal structure decisions and encumbrances continuing to affect the future, etc.) - perhaps a better 'vehicle' for tax savings for the US railroads would be a "Master Limited Partnership" ("MLP") structure for their real estate assets. 

This is often used by pipeline companies for that reason, mainly because of their extensive real estate holdings that are necessary as part of their operations, which is also an IRS requirement for that kind of tax treatment.  However, Kinder Morgan has been in the news recently because they are going to unwind their MLP and go back to a more normal corporate structure to facilitate future financing, etc.

- Paul North. 

"This Fascinating Railroad Business" (title of 1943 book by Robert Selph Henry of the AAR)
  • Member since
    September 2007
  • From: Charlotte, NC
  • 6,099 posts
Posted by Phoebe Vet on Thursday, August 28, 2014 5:52 AM

 "We don't pay taxes. Only the little people pay taxes."

Leona Helmsley

Dave

Lackawanna Route of the Phoebe Snow

  • Member since
    February 2003
  • From: Guelph, Ontario
  • 4,819 posts
Posted by Ulrich on Thursday, August 28, 2014 10:22 AM

Her famous last words prior to her IRS audit. 

  • Member since
    July 2006
  • From: Somewhere in North Texas
  • 1,080 posts
Posted by desertdog on Thursday, August 28, 2014 3:19 PM

Phoebe Vet

 "We don't pay taxes. Only the little people pay taxes."

Leona Helmsley

What does this have to do with corporate taxes?

John Timm

  • Member since
    May 2003
  • From: US
  • 25,292 posts
Posted by BaltACD on Thursday, August 28, 2014 4:04 PM

desertdog

Phoebe Vet

 "We don't pay taxes. Only the little people pay taxes."

Leona Helmsley

What does this have to do with corporate taxes?

John Timm

Leona was the head of the Helmsley hotel chain which was a corporation with outlets throughout the country..

Never too old to have a happy childhood!

              

  • Member since
    July 2006
  • From: Somewhere in North Texas
  • 1,080 posts
Posted by desertdog on Thursday, August 28, 2014 4:39 PM

BaltACD

desertdog

Phoebe Vet

 "We don't pay taxes. Only the little people pay taxes."

Leona Helmsley

What does this have to do with corporate taxes?

John Timm

Leona was the head of the Helmsley hotel chain which was a corporation with outlets throughout the country..

Yes, I'm familiar with Leona. A pathetic individual.

It just seems that the quote has more to do with personal income taxes than corporate. 

John Timm

  • Member since
    September 2007
  • From: Charlotte, NC
  • 6,099 posts
Posted by Phoebe Vet on Thursday, August 28, 2014 4:46 PM

Corporate tax rates are largely meaningless.  The tax code is thousands of pages of convoluted language and large corporations have entire departments full of people who manipulate the books and exploit the loopholes.  Moving the corporate headquarters has little effect on the taxes they pay on income earned in the US, just as having their HQ here has little effect on the taxes they pay here on off shore profits.  It is not that simple.  If moving off shore could get you out of paying US taxes then there wouldn't be a Toyota of America building cars in Ohio.

Dave

Lackawanna Route of the Phoebe Snow

  • Member since
    December 2001
  • From: US
  • 17 posts
Posted by ChrisB1962 on Thursday, August 28, 2014 9:36 PM
The difference in taxes is that the US taxes all profits of US domiciled companies at the US rate (one of the highest rates in the world) while practically every other country applies the tax rates applicable in the country of origin to the portion of earnings from that country. BK will continue to pay US taxes on its US earnings but Canadian rates on Canadian earnings, and so on. There has been a lot of misinformation spread about BK paying NO taxes in the US after the change which is untrue. I don't see a way many railroads would benefit from this since unless they have significant operations outside the US it would have ZERO impact on their US taxes. CN and CP are already Canadian based. KCS might be able to benefit since it has operations in Mexico though I don't know if they could create a corporate structure that could take advantage of it.
  • Member since
    May 2004
  • From: Valparaiso, In
  • 5,921 posts
Posted by MP173 on Friday, August 29, 2014 8:24 AM

I am not an accountant but I do know enough that our tax code is pretty messed up.

Many of our large corporations, lets use Coca Cola as an example, are multinational.  The majority of Coke's revenues and earnings are outside the US.  About 80% in fact.  As I understand it, when a company brings that money back into the US, then it triggers taxes on those earnings.  Thus, you find a number of companies keep the foreign earnings offshore and invest there or simply hoard cash.  Take a look at Coke's balance sheet the past 10 years and one will see how debt has increased dramatically?  Why?  In order to pay dividends to shareholders and to keep from paying the high US tax rate on these earnings.

Coke and others are hoping for a tax holiday or tax restructuring.  Meanwhile the current administration screams this is "unpatriotic".  They are asking a corporation to have a "soul" and do the right thing, yet they do not want a corporation to have an identity as a person and "do the right thing" in cases such as Hobby Lobby.

It is all rather simple...streamline the tax code.  Capital will continue to leave the United States if this is not done.  Senator Durbin of Illinois can bully Walgreens this year, but at some point in time it will not work.  Was Durbin instrumental in Boeing moving to Chicago a few years ago?  Hmm.  Again, having it both ways.

Ed

Join our Community!

Our community is FREE to join. To participate you must either login or register for an account.

Search the Community

Newsletter Sign-Up

By signing up you may also receive occasional reader surveys and special offers from Trains magazine.Please view our privacy policy