Ireland's The Business Post Reports that Coca-Cola Transferred 4.4 Billion Euros from Ireland to the Cayman Islands to 'Pay Dividends,' with Less U.S. Taxes Paid

The Business Post has reported new details on Coca-Cola's evasive tax strategy paying €4.4 billion in dividends to a Cayman Islands entity, already scrutinized by U.S. Tax Court, which indicated that Coca-Cola owes around $6 billion in back taxes and interest. 

Money Sent to Cayman Islands

The IRS is Investigating Coca-Cola's Offshore Tax Strategy

The Business Post reported that a significant amount dividends was paid to an entity in the Cayman Islands, and these dividends were paid from its Irish office - an office being scrutinized by the U.S. Internal Revenue Service (IRS). According to the article, the IRS is "probing whether Coca-Cola had moved profits from its U.S. tax base and allocated it to its Irish Operation, which then paid the money to the Cayman Islands, an offshore entity.

Yahoo! Finance reported that U.S. Tax Court found that Coca-Cola has hidden "astronomical levels" of profits in low-tax jurisdictions - one of which being Ireland - and that Coca-Cola owes the IRS about $6 billion USD. The other subsidiary named was it's Brazil subsidiary, which together could result in a combined $16 billion owed to the U.S.

Yahoo! Finance reported:

"The Irish subsidiary's tax rate tells a striking story. Back in 2017, the company paid a mere 1.32% on what it earned from operations. That rate rose to 7.88% by 2023 but fell again to 5.87% last year after the company claimed over 239 million euros ($280 million) in tax relief." -Leslie Sattler of Yahoo! Finance

Per the Business Post article, this is not the first time Coca-Cola's Irish subsidiary has been involved in a tax dispute with the U.S. 

The U.S. Internal Revenue Service (IRS) has been disputing Coca-Cola’s transfer pricing arrangements involving its Irish operation going back at least to the mid-2010s, with formal litigation and major rulings tied to profit allocations for tax years as early as 2007–2009. The IRS designated the case for litigation in 2015, kick-starting a long-running dispute over whether profits were artificially shifted offshore to subsidiaries in low-tax jurisdictions, including Ireland.

Reported by The Irish Times:

A U.S. Tax Court judgment from 2020 highlighted that Coca-Cola had manipulated profit allocations to its Irish unit—among others—leading to an extremely low effective tax rate and prompting orders for billions in back taxes and interest. This has been part of a long-running tax fight covering roughly a decade and continuing into appeals and related scrutiny. 

CFO: "The Company is Confident"

Chief Financial Officer John Murphy said the company is confident.

"We have outside counsel who have, each quarter, continued to evaluate the case on the facts that are available to them, and they continue to offer an opinion that gives us a greater-than-not chance of prevailing," he said.

Should Companies Like Coca-Cola Pay a Flat 15% Global Minimum Tax Rate?

To make things fair across the board, some believe that a global minimum tax rate should be instituted for all international companies. That way, large corporations could not have an option to evade taxes by moving revenues to overseas operations or offshore entities.

Yahoo! Finance also reported:

"What's being done about corporate tax avoidance?

More than 140 countries have agreed to a 15% global minimum corporate tax through the OECD, an effort meant to close loopholes that let companies shift profits to havens.

Meanwhile, the U.S. continues pursuing its case against Coca-Cola, with the company fighting the ruling on appeal."

Movie Review: Downsizing (2017) is Dull and Bores with Global Warming

Downsizing

Downsizing: Don't Think that it is a Fun Movie

A friend and I went to see the movie Downsizing (2017). It was between this movie and All the Money in the World (2017). My friend decided that the Downsizing movie would be less of a downer (less depressing) and that it would be a fun and lighthearted movie. Boy, was he wrong. It is not a comedy. It is a dull and depressing movie about how the Earth will end at the hands of methane gas due to Global Warming.

This movie was dull and depressing and boring. The movie was disappointing and I will tell you why.

The following contains spoilers.

The Downsizing Trailer is Misleading

First of all, if you get the impression that the movie Downsizing is a fun and lighthearted movie from the trailer, then you are sadly mistaken.

I thought the movie was going to be similar to Honey I Shrunk the Kids (1989), in that they would exploring the nuances of being shrunk and small in comparison to the rest of the world. Downsizing is not like this at all. There are only a few moments in the movie where this happens.

First, Matt Damon plays lead character Paul Safranek. He is an occupational therapist that is a middle class guy working in Omaha Steaks in the Midwest. So he and his wife agree to be shrunk so they can multiply their wealth (the small lifestyle requires less money to life and the money goes farther).

So we get to see the process of Paul Safranek getting shrunk. They have to remove all of his hair from his body, and all of the fillings from his mouth. This is because any non-living tissue would stay the real size, and kill the person during the shrinking process.

Downsizing: Only a Few References to Being Small

Here are the following references in the movie to being small:

The opening speaker: Dr. Jorgen Asbjørnsen 

In the movie, it starts with the guy that invents the shrinking process. Dr. Jorgen

He speaks to a group of people, and they are impressed with the small footprint that a tiny person creates.

The high school  reunion: This the second encounter when a couple from high school is carried into the reunion in a glass box.

After Paul Safranek is shrunk, and handed over from the normal size nurse to the minature nurses, the normal nurse is chatting with the minature nurses. This is one example of the cross reference between large and small. The next example is when Paul Safranek wakes up, the nurse shows him a pack of large Saltine crackers, and mentions how cute that is. After this, the only other reference to them being small is when they travel on a bus, because normal size people and miniatures can travel on the same bus.

Aside from the examples given above, the movie imagery veers heavily from the whole premise of being small. After about the halfway mark of the movie, they do not show any more size comparisons or normal to miniature comparisons.

Downsizing Stays Depressing Throughout the Movie

The overarching them throughout the movie Downsizing is Global Warming. This is no secret. From the start of the movie, Dr. Jorgen and his colleagues present their process at a conference in Turkey.

Then we go into the future. This happens quite a bit throughout the movie. Five Years Later. One Year Later. Five Years Later. etc. This is just one sign that the movie can't tell a continuous story about anything interesting.

Overall, the movie is quite depressing. Paul Safranek is taking care of his sick mother. Paul Safranek is not able to buy the house his wife really wants. Paul Safranek's wife divorces him because she gets cold feet when about to be shrunk. Lastly, Dr. Jorgen says that methane has been released at the Antarctic and the Earth will no longer sustain life.

In terms of a positive uptick in the movie, the only positive is that Paul Safranek falls in love with a Vietnamese refugee, and this takes up the majority of the second half of the movie. He says that he finally understands his purpose in life, and wants to go with the original small community underground for thousands of years. However, he changes his mind at the last minute, because he is in love with the Vietnamese refugee woman.

I found myself wondering: "How much longer will this movie last?" many times, and the movie seemed to drag on. It failed to deliver.

To sum it all up, this movie is not a lighthearted comedy movie about being shrunk. It is a heavily political movie focused on the effects of Global Warming hysteria.

Regardless of your stance on Global Warming, this movie felt incomplete and disjointed at best. I left the movie feeling unsatisfied. I would not willingly want to watch this movie ever again. That would be torture. It's that bad.