Geithner targets overseas earnings

THE 2012 foreign investment harvest is starting to look pretty good.

One thousand Pay Pal jobs in Dundalk. A €350m investment by Allergen in Westport, Co Mayo. An €85m investment by Abbott in Sligo.

Hewlett Packard, Accenture, Mastercard, and Big Fish have all been on the expansion trail in recent weeks. Google, Facebook, and Linkedin are all looking for extra office space in Dublin.

Ireland accounts for one sixth of all US foreign direct investment in Europe.

Without this source, our export-led growth would surely be tapering off,leaving the economy even deeper in the mire.

The Government has placed a lot of faith in FDI, lining up key allies in support of the cause.

In New York a fortnight ago, Bill Clinton pulled together a large host of the corporate great and good and proceeded to promote investment into Ireland as a no-brainer.

Few countries can boast such allies.

Yet, down the road in Washington, events are unfolding that could alter matters considerably.

US President Barack Obama and his treasury secretary, Timothy Geithner, have unveiled an ambitious plan aimed at overhauling the US tax system.

The plan, developed by Geithner, involves an overhaul in business taxation, with a reduction in the main company tax rate from 35% to 28% and the introduction of a 25% rate for manufacturers.

This would be financed through the elimination of dozens of loopholes and a new minimum tax on the foreign earnings of overseas affiliates of US multinationals.

As Obama put it: “It is time to stop rewarding businesses that ship jobs overseas”.

Ireland has gained a reputation as Europe’s leading tax haven, with companies such as Google and Microsoft routing large amounts of profit through this country in an effort to cut their tax bills. Some economists believe it is only a matter of time before such activities face a serious crackdown.

However, senior tax advisers appear to take a more sanguine view of developments.

One former managing partner of a leading accounting firm said: “I have been hearing about such proposals for 30 years. Obama can propose. Congress may dispose. The US business chambers are very strongly organised. If a company needs to be abroad, why should the US government be taxing them? Corporate profits are used to help the business expand. Higher taxes would make these businesses less competitive.”

According to another tax adviser, the plan has emerged to coincide with election year in the US. This source questions why a multinational should have to pay tax to the US federal government on profits earned elsewhere.

“International transfer pricing rules — on the allocation of profit between territories — have been agreed by the OECD.”

What is happening is that various tax authorities are seeking, in effect, to expand their tax base.

This is not the first time Geithner has appeared on Irish radar screens. He is viewed by many as the dark side of an otherwise friendly US administration.

Last year, UCD economist Prof Morgan Kelly suggested Geithner had intervened to scupper an IMF proposal that bondholders bear a large part of the burden of debt falling on the country. Geithner briefly became a national hate figure, accused of killing a proposed two-thirds haircut involving €30bn in unguaranteed bonds.

In the US, too, some critics suggest Geithner has been far too quick to steer Federal largesse in the direction of bust financial institutions, having supped far too closely with the Wall St devil.

What is clear is that he has served as a lightning rod, absorbing much of the flak that would otherwise be directed at the president.

The pair are exceptionally close. Both were born in Aug 1961 and both spent much of their childhood in Asia, where a parent in each case worked for the US government.

Both enjoy youthful pastimes. While Obama favours basketball, Geithner has enjoyed snowboarding and skateboarding.

But whereas the president came to office through civic activism and the Chicago school of political hard knocks, Geithner followed the gilded path of the financier-technocrat.

Having learned Japanese at university, he got a job in the US embassy in Tokyo. His first big job was as a junior minister in the Clinton administration under then treasury secretary Robert Rubin, the Goldman Sachs banker who pushed through financial deregulation.

Geithner moved to the IMF as policy director before joining the New York Federal Reserve Bank as president.

There, he was involved in setting monetary policy for the country as a whole, as a member of the US Federal Reserve board, and must carry some of the can for the financial bubble.

In 2008, he was involved in bailing out Bear Stearns and was later implicated in the decision to let Lehmans Bank go under, an event that had cataclysmic consequences for many.

As treasury secretary, Geithner, has tried to follow Keynesian policies, pumping up the labour market, but has come up against a brick wall in Congress, which has been dominated since 2011 by the Republicans. He has also been an interested party in the eurozone crisis, trying to persuade the Germans and ECB to be more flexible in their approach to the crisis.

Behind the scenes, he has been critical in the attempts to defuse the crisis, aware of its potential to disrupt the global economy.

The longest-surviving of Obama’s original team of economic advisers, Geithner is expected to leave government to pursue lucrative opportunities in the private sector, having played his part in helping the US economy to stage an election-year recovery.

It remains to be seen whether his tax plan could yet leave a real sting in the tail as far as Ireland is concerned, or turn out to be just another example of sabre rattling aimed at the home audience.

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