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The Paradise Papers: After a Tax Crackdown, Apple Found a New Shelter for Its Profits

Seeking ‘the Holy Grail’Since the mid-1990s, multinationals based in the United States have increasingly shifted profits into offshore tax havens. Indeed, a tiny handful of jurisdictions — mostly Bermuda, Ireland, Luxembourg and the Netherlands — now account for 63 percent of all profits that American multinational companies claim to earn overseas, according to an analysis by Gabriel Zucman, an assistant professor of economics at the University of California, Berkeley. Those destinations hold far less than 1 percent of the world’s population.Continue reading the main storyCriticism of such profit shifting was largely ignored until government finances around the globe came under pressure in the years following the 2008 financial crisis, when the practice led to government inquiries, tax inspector raids, media scrutiny and promises of reform.In May 2013, the Senate’s investigative subcommittee released a 142-page report on Apple’s tax avoidance, finding that the company was attributing billions of dollars in profits each year to three Irish subsidiaries that declared “tax residency” nowhere in the world.Under Irish law, if a company can convince Irish tax authorities that it is “managed and controlled” abroad, it can largely escape Irish income tax. By seeming to run its Irish subsidiaries from its world headquarters in California, Apple ensured that Irish tax residency was avoided.At the same time, American law dictated that the subsidiaries were only tax residents in the United States if incorporated there. The federal government permits taxes on any income generated by foreign units to be deferred indefinitely, as long as the company says those profits stay offshore.U.S. Profits Made in Offshore Tax Havens IncreaseThe share of U.S. companies’ foreign profits attributed to a handful of tax havens has more than doubled in past 20 years.%604020063%2000200520102015“Apple has sought the holy grail of tax avoidance: offshore corporations that it argues are not, for tax purposes, resident anywhere in any nation,” then-Senator Carl Levin, Democrat of Michigan, who was the subcommittee chairman, said at the 2013 hearing.Ireland’s finance minister at the time, Michael Noonan, at first defended his country’s policies: “I do not want to be the whipping boy for some misunderstanding in a hearing in the U.S. Congress.” Ireland had long pursued business-friendly tax policies, which helped lure jobs to the country, primarily for technology and pharmaceutical companies. Apple now has about 6,000 employees in Ireland, including customer service and administrative jobs.But by October 2013, in response to growing international pressure, Mr […]

On Medicine : Can Heart Disease Shed Light on Cancer?

Cardiologists learned that they could prevent plaque accumulation by changing diet or habits or by using cholesterol-lowering drugs like Lipitor. Beyond prevention, the doctors could forcibly widen the arterial blockade or inject clot-busting drugs. The image of scales of lead clogging old pipes, and a Roto-Rooter, was hard to shake. Coronary artery disease, it seemed then, was mainly a plumbing problem, demanding a plumber’s toolbox of solutions (to be fair, there’s a cosmos of biology behind cholesterol metabolism and its link to heart disease).PhotoCancer, by contrast, was an exterminator’s problem — a poisoner’s dilemma. Cancer-causing agents unleashed abnormal cellular proliferation by mutating genes involved in regulating growth. These cancer cells, occupying tissues and spreading, demanded a cellular poison — chemotherapy — that would spare normal cells and kill the malignant ones.Cardiologists and oncologists — plumbers and poisoners — lived in different medical realms. We spoke different languages, attended different conferences, read different specialty journals. If our paths intersected, we considered the crossing coincidental, the unavoidable convergence of two common age-related illnesses on the same body.Continue reading the main storyI was a medical resident in Boston in the early 2000s when I heard a theory that would, in time, force these separate worlds to collide. Two cardiologists, Peter Libby and Paul Ridker, were thinking about plaque formation in a different way. Libby and Ridker acknowledged the role of cholesterol and lipids […]

Is Germany Still a Haven for Israelis? After Election, Some Wonder

Were the very things that have made Germany seem so safe to so many Israelis — the national preoccupation with contrition, aversion to raw nationalism, and determination never to repeat the sins of the past — now in danger of being shunted aside by a new generation unburdened by collective guilt and determined to assert its national identity?Was Israel’s special relationship with Germany, too, now in danger?Prime Minister Benjamin Netanyahu hastened to say that it was not, announcing Tuesday that he had spoken with Chancellor Angela Merkel. He congratulated her on winning and expressed confidence that Israel and Germany would only deepen their ties.But Mr. Netanyahu added that Israel was “concerned about the rise of anti-Semitism” on both the political right and left, and noted that “there are two different things: denying the Holocaust and denying responsibility.” He called on Ms. Merkel’s new government to “act to strengthen the forces in Germany that take on the historical responsibility.”Among the opposition, Amir Peretz, a Knesset member from the left-of-center Zionist Union, wrote on Twitter in German that the election was “a bad day for Germany democracy, with the entry of xenophobes and open anti-Semites into the Bundestag.”Yet like so much else dividing Israeli society today, the advances by the Alternative for Germany, or the AfD, as it is known, seems to provide more of an excuse for political recriminations and partisan bile than a source of common Jewish ground.On the right, there was newfound scorn, and worse, for Israeli expatriates in Germany.Aryeh Eldad, a former Knesset member and medical professor, wrote in Maariv of his revulsion at the “20,000 Israelis who moved from Israel to Germany of their own free will,” whether for “cheaper housing and cheaper cottage cheese” or to live under “the wonderful German democracy” out of a “distorted” leftism. Both groups, he said, were “emotional cripples.”“These Israelis,” Mr. Eldad wrote, “are not like the dog that comes back to eat his own vomit, but rather like the vomit that returns to the dog that spewed it.”Continue reading the main storyOn the left, there was renewed criticism for the Israeli government that so many left behind when they moved to Germany.Michael Sappir, a 29-year-old in Tel Aviv who earned a degree in linguistics at the University of Leipzig, in Saxony, and now works in high tech, said the election “makes me think twice about the idea of moving there again, both as a Jew and a leftist.”But, he added, “the situation in Germany is much, much better than here, where the governing coalition is composed mostly of parties that are intellectually akin to the AfD.” He said, “What’s considered the terrifying right wing there is on many policy points just mainstream here.”Newsletter Sign UpContinue reading the main storyThank you for subscribing.An error has occurred. Please try again later.You are already subscribed to this email.View all New York Times newsletters.Even after Sunday’s election, Mr. Sappir said, he still believes he would be safer in Germany than in Israel. “The norms of governance, the rule of law, there is much stronger,” he said. “Here I feel like an embattled minority. […]

Trump’s Next Move on Health Care? Choice for Secretary May Offer Clue

The White House had no comment on Saturday, but two advisers who asked not to be identified discussing internal matters said two top candidates were Scott Gottlieb, the commissioner of the Food and Drug Administration, and Seema Verma, the administrator of the Centers for Medicare and Medicaid Services. Both have previously been vetted by the White House, nominated by the president and confirmed by the Senate to their current jobs within recent months, a significant selling point.Other names have been floated as well, including David Shulkin, the secretary of veterans affairs and a favorite of the president’s. But he has been criticized for a European trip with his wife that mixed business and sightseeing and was partially financed by taxpayers, and Mr. Trump may be reluctant to move him because he has been critical to fixing veterans’ care.Some reports floated former Gov. Bobby Jindal of Louisiana, an assistant secretary of health and human services under President George W. Bush. But he was a caustic critic of Mr. Trump during his own brief campaign for the White House that ended in late 2015 after he called the future president a “narcissist” and “egomaniacal madman.”Mr. Trump may not necessarily fill the post quickly. […]

Immigration Officials Taking New Steps to Discourage Smuggling of Children

“The risks associated with smuggling children into the U.S. present a constant humanitarian threat,” ICE officials said in a statement. “The sponsors who have placed children directly into harm’s way by entrusting them to violent criminal organizations will be held accountable for their role in these conspiracies.”Newsletter Sign UpContinue reading the main storySign Up for the Race/Related NewsletterJoin a deep and provocative exploration of race with a diverse group of New York Times journalists.Thank you for subscribing.An error has occurred. Please try again later.You are already subscribed to this email.View all New York Times newsletters.Some children reported being raped or held hostage by smugglers for more money. Others have been abandoned by smugglers as they try to cross the border.Immigration advocates called the new enforcement policy a heartless way to try to reduce smuggling.“It’s extremely cruel when you started shutting down refugee applicants and rescinding protections for children brought to the country at a young age, to send this kind of message to parents trying to get their kids to safety,” said Chris Rickerd, policy counsel with the American Civil Liberties Union in Washington.Smuggling cases are among the most challenging to prove, and the biggest hurdle is identifying witnesses, who are likely to be undocumented and unwilling to help, according to Michael J […]

News Analysis: Is Trump All Talk on North Korea? The Uncertainty Sends a Shiver

Veterans of diplomacy and national security and specialists on North Korea fear that, whatever their intended result, Mr. Trump’s increasingly bellicose threats and public insults of the famously thin-skinned Mr. Kim could cause the United States to careen into a nuclear confrontation driven by personal animosity and bravado.“It does matter, because you don’t want to get to a situation where North Korea fundamentally miscalculates that an attack is coming,” said Sue Mi Terry, a former intelligence and National Security Council specialist who is now a senior adviser for Korea at Bower Group Asia. […]

News Analysis: Yes, Aaron Hernandez Suffered Brain Injury. But That May Not Explain His Violence.

Yet drawing a direct line from those basic findings to what people do out in the world is dicey, given the ineffable interplay between circumstance, relationships and personality.What scientists — from such diverse fields as psychiatry, neurology and substance use — can say is that the arrows seem to be pointing in the same direction. A number of brain states raise the risk of acting out violently, and the evidence so far, while incomplete, suggests that C.T.E. may be one of them.PhotoFormer New England Patriots tight end Aaron Hernandez during his arraignment in Boston in 2014. While the damage to the brain of Mr. Hernandez was extensive, the science linking chronic traumatic encephalopathy and violent behavior is still murky.Credit Pool photo by Dominick ReuterDr. Samuel Gandy, director of the N.F.L. neurology program at Mount Sinai Medical Center, said that rage and irritability “are far and away the most prominent symptoms” among former players with likely C.T.E., in his research. […]