Should Burger King Acquire Tim Hortons?

Maria-Kay's picture
Rank: Baboon | banana points 122

Burger King is in talks to create what would be the third largest fast food company in the world with the iconic (to Canadians anyway) Tim Hortons. Let us know what you think. Great deal, or just another company fleeing the US tax system?

http://www.firmex.com/blog/should-burger-king-acqu...

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Comments (75)

Aug 25, 2014

I enjoyed Tim Horton's while on work trip in Michigan, it's definitely in the same genre as BK, i.e. Stuff I Shouldn't Eat Everyday. Without seeing one line of financials, that part at least makes it a good fit.

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Aug 25, 2014

That would be soooooo weird.

It would be kinda like McDonald's buying Dunkin Donuts.....like no. That's just too much in 1 space. And it's weird.

Like are they trying to become the Wal-Mart of fast-food by doing that? So weird.

Aug 27, 2014

I don't think they'd be putting each others' products in current stores. There's be consolidations on the corporate side, but they'd probably still franchise as separate entities.

Aug 25, 2014

3G Capital took Burger King private in 2010 at a valuation of $4 billion. Burger King's current market cap is $9.73B and 3G Capital still retains a 70% stake or $6.81 billion equity stake.
3G Capital used to have substantial investments in Wendy's and Jack in the Box. At the time of those investments Wendy's used to own Tim Horton's before they spun it out in 2006.

These guys at 3G Capital know what they're doing.

Robert Clayton Dean: What is happening?
Brill: I blew up the building.
Robert Clayton Dean: Why?
Brill: Because you made a phone call.

Aug 25, 2014

Well, you could say that Burger King is looking to try and actually compete with McDonald's' but it strikes me that they already offer breakfast... although I've never actually had it to my knowledge.

That said, I love the young guys they have running the show at burger king with their franchising plays and vicious cost cutting... so, why not? It's not like they are buying a Canadian makeup company or something.

Aug 25, 2014

Although I think this has inversion deal written all over it, if it can be levered to bring Tim Horton's into the US without making is a "Dual Brand" Store (think the KFC/A&W Combos, etc.), then I'm all for it. I happen to like Tim Horton's and think that it's a fantastic brand. I prefer it to Dunkin, Starbucks and McDonald's Coffee. The Doughnuts are ok, but the real gem is the Coffee with an occasional does of Timbits. Financially, if it makes sense, then it go for it.

Aug 25, 2014

Tax benefits for no longer paying double taxes on profits earned abroad - check
Improving breakfast offerings and quality - check
Synergies - check
Consolidating in a declining segment - check

What isn't to like about this acquisition?

Aug 28, 2014

Those Timbits are so good haha.

I'm too drunk to taste this chicken -Late great Col. Sanders

Aug 25, 2014

These inversion deals need to be banned asap! Complete horseshit in my opinion. We're basically creating a free market for corporate tax rates, which can lead to some very nasty outcomes... pretty soon the U.S. won't have any corporate tax revenue and will have to turn the screws hard on individuals and small biz owners.

I guess I should be writing my congressman, instead of you guys...

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Aug 25, 2014
jankynoname:

These inversion deals need to be banned asap! Complete horseshit in my opinion. We're basically creating a free market for corporate tax rates, which can lead to some very nasty outcomes... pretty soon the U.S. won't have any corporate tax revenue and will have to turn the screws hard on individuals and small biz owners.

I guess I should be writing my congressman, instead of you guys...

Instead of banning inversions, why not fix what is a completely fucked tax system? 35% and taxing foreign revenues is completely ridiculous. If the US had a tax system comparable to most developed countries these inversion deals would never have arisen.

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Aug 25, 2014
jankynoname:

These inversion deals need to be banned asap! Complete horseshit in my opinion. We're basically creating a free market for corporate tax rates, which can lead to some very nasty outcomes... pretty soon the U.S. won't have any corporate tax revenue and will have to turn the screws hard on individuals and small biz owners.

I guess I should be writing my congressman, instead of you guys...

Ding Ding! Totally agree. An people wonder why the upper middle class gets f*ck when it comes to taxes.

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Aug 26, 2014
LIFinancier:
jankynoname:

These inversion deals need to be banned asap! Complete horseshit in my opinion. We're basically creating a free market for corporate tax rates, which can lead to some very nasty outcomes... pretty soon the U.S. won't have any corporate tax revenue and will have to turn the screws hard on individuals and small biz owners.

I guess I should be writing my congressman, instead of you guys...

Ding Ding! Totally agree. An people wonder why the upper middle class gets f*ck when it comes to taxes.

Upper middle class: Making enough money to get taxed a ton, not making enough money to effectively sidestep getting taxed a ton.

Aug 27, 2014
DoubleEagle:

Upper middle class: Making enough money to get taxed a ton, not making enough money to effectively sidestep getting taxed a ton.

Story of my G.D. life...

Aug 25, 2014
jankynoname:

These inversion deals need to be banned asap! Complete horseshit in my opinion. We're basically creating a free market for corporate tax rates, which can lead to some very nasty outcomes... pretty soon the U.S. won't have any corporate tax revenue and will have to turn the screws hard on individuals and small biz owners.

I guess I should be writing my congressman, instead of you guys...

A free market that exists in virtually every other country in the world; hence, the incentive to invert in the first place.

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Aug 26, 2014
NorthSider:
jankynoname:

These inversion deals need to be banned asap! Complete horseshit in my opinion. We're basically creating a free market for corporate tax rates, which can lead to some very nasty outcomes... pretty soon the U.S. won't have any corporate tax revenue and will have to turn the screws hard on individuals and small biz owners.

I guess I should be writing my congressman, instead of you guys...

A free market that exists in virtually every other country in the world; hence, the incentive to invert in the first place.

Hey man, no one is forcing these companies to do business in the U.S. If they don't want to have access to our market, our employees, the implicit guarantees that come from a strong defense, stable currency, sophisticated legal system, halfway decent infrastructure etc., then they are welcome to take their businesses elsewhere. If they do want to participate, then they need to pay their fair share to support the U.S.

It's just crazy because if you have a free market for tax rates it's like borders don't mean anything anymore. Everyone will end up "pricing" at the same tax rate, and all economies will basically play an allocation game with what they get to spend those tax dollars on (defense, education, infrastructure, etc.). Borders should mean something and different countries should have an ability to price for government services depending on their needs. I also think it's silly because a lot of these countries have low corporate tax rates but higher individual rates. If the principals and top shareholders of these inverted companies want to get the tax benefit on the corporate side, they should be willing to pay the higher individual income tax rate. Take it all or nothing.

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Aug 26, 2014

Hate to break it to you but America isn't as great as it used to be. Of the accesses you highlight in your post, the only one that is a certainty for the future is a strong defense which is because we spend an absurd amount of money on it. Sure other economies plays the same allocation game but clearly they are doing better than we are because they spend less of their budgets on defense, education, etc. but yet they still have a sustainable defense and most have a far better primary and secondary education system than the US. The US's problem of companies leaving is a result of a government that needs far too much money to operate.

Best Response
Aug 26, 2014
jankynoname:

Hey man, no one is forcing these companies to do business in the U.S. If they don't want to have access to our market, our employees, the implicit guarantees that come from a strong defense, stable currency, sophisticated legal system, halfway decent infrastructure etc., then they are welcome to take their businesses elsewhere. If they do want to participate, then they need to pay their fair share to support the U.S.

It's just crazy because if you have a free market for tax rates it's like borders don't mean anything anymore. Everyone will end up "pricing" at the same tax rate, and all economies will basically play an allocation game with what they get to spend those tax dollars on (defense, education, infrastructure, etc.). Borders should mean something and different countries should have an ability to price for government services depending on their needs. I also think it's silly because a lot of these countries have low corporate tax rates but higher individual rates.

"Pricing"? I have no idea what you're talking about, but I suspect - given my previous experience with your posts - that you are once again opining on a topic about which you lack even basic understanding.

Companies, like BK, that transact business in the U.S. pay U.S. corporate tax rates, regardless of domicile. Should the BK / TH deal be consummated, BK will continue to pay U.S. corporate taxes on income it earns in the country.

The difference between the U.S. corporate tax regime and that of virtually every other globally significant country is territoriality. Corporations domiciled in the U.S. are expected to pay 35% income taxes on any and all earnings, worldwide. Contrarily, in Canada, France, Germany, Japan, UK, Switzerland, etc. (including many of what I imagine fit your vision of collectivist utopias), companies pay domestic income taxes on domestic income and pay local rates for foreign income.

For instance, today, BK pays 35% on income it earns in Canada, despite the fact that Canadian income tax rates are in the high teens or low twenties including municipal taxes. After transaction completion, it will pay Canadian income taxes on Canadian income and U.S. taxes on U.S. income. Said differently, it will pay taxes in accordance with the global norm, rather than the exceptionalist U.S. corporate tax regime that seeks to take its share of every penny.

In short, contrary to your point above, there will be no "repricing" of corporate tax rates, companies will continue to pay their "fair share". But they should, and likely will, relocate to avoid paying taxes under the U.S.'s usurious policy of taxing income earned beyond its borders.

If the principals and top shareholders of these inverted companies want to get the tax benefit on the corporate side, they should be willing to pay the higher individual income tax rate. Take it all or nothing.

I've broken this section out because it is specifically and quite hilariously ludicrous.

1) Can we just note the fact that, despite your overarching complaint that corporations / people are taking measures to avoid paying U.S. taxes, you're suggesting that the officers of inverted companies should pay foreign taxes, in lieu of U.S. taxes. What's particularly illuminating about this observation is that it highlights your true policy goal: to take money away from those you perceive to be "too rich", rather than your putative goal of "giving to the poor". You'd rather executives be taxed at a higher rate by a foreign country (to the chagrin of U.S. tax revenue) than have their tax dollars benefit the poor in the U.S. Moreover, I suspect if corporations began redomiciling in, say, Switzerland, where personal income tax rates are lower than those in the U.S., you would recant this position in favor of higher rates in the U.S. Your argument has nothing to do with principle ("take it all or nothing"), and everything to do with your personal vendetta against corporations / the wealthy (which you seem to treat as a common enemy)

2) Let's also appreciate how backwards the world would be if, say, AT&T call center representatives in Bangalore had to pay U.S. income taxes on their earnings because AT&T is domiciled in the U.S. You can't possibly hold this position.

3) As for "top shareholders", they obviously already are subject to foreign tax regimes on foreign investment income. Yet another irrelevant concern.

---

Once again, I suggest you spend some time reading and considering your point of view before offering it on a public forum.

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Aug 26, 2014
NorthSider:
jankynoname:

Hey man, no one is forcing these companies to do business in the U.S. If they don't want to have access to our market, our employees, the implicit guarantees that come from a strong defense, stable currency, sophisticated legal system, halfway decent infrastructure etc., then they are welcome to take their businesses elsewhere. If they do want to participate, then they need to pay their fair share to support the U.S.

It's just crazy because if you have a free market for tax rates it's like borders don't mean anything anymore. Everyone will end up "pricing" at the same tax rate, and all economies will basically play an allocation game with what they get to spend those tax dollars on (defense, education, infrastructure, etc.). Borders should mean something and different countries should have an ability to price for government services depending on their needs. I also think it's silly because a lot of these countries have low corporate tax rates but higher individual rates.

"Pricing"? I have no idea what you're talking about, but I suspect - given my previous experience with your posts - that you are once again opining on a topic about which you lack even basic understanding.

Companies, like BK, that transact business in the U.S. pay U.S. corporate tax rates, regardless of domicile. Should the BK / TH deal be consummated, BK will continue to pay U.S. corporate taxes on income it earns in the country.

The difference between the U.S. corporate tax regime and that of virtually every other globally significant country is territoriality. Corporations domiciled in the U.S. are expected to pay 35% income taxes on any and all earnings, worldwide. Contrarily, in Canada, France, Germany, Japan, UK, Switzerland, etc. (including many of what I imagine fit your vision of collectivist utopias), companies pay domestic income taxes on domestic income and pay local rates for foreign income.

For instance, today, BK pays 35% on income it earns in Canada, despite the fact that Canadian income tax rates are in the high teens or low twenties including municipal taxes. After transaction completion, it will pay Canadian income taxes on Canadian income and U.S. taxes on U.S. income. Said differently, it will pay taxes in accordance with the global norm, rather than the exceptionalist U.S. corporate tax regime that seeks to take its share of every penny.

In short, contrary to your point above, there will be no "repricing" of corporate tax rates, companies will continue to pay their "fair share". But they should, and likely will, relocate to avoid paying taxes under the U.S.'s usurious policy of taxing income earned beyond its borders.

This is a good description. I didn't learn anything new here, but others might. Global vs. territorial taxation will certainly be an important topic whenever we have a congress that is remotely capable of discussing comprehensive tax reform without reverting to politardism. Until then, we need to stop the bleeding and block companies and their sponsors from fleeing Merica. Near term this is a tax issue. Long-term, this is about jobs, GDP, allocation of strategic resources, etc. Congress as usual is asleep at the wheel.

Do you guys really want to be paying fuck-high individual income taxes in 5 years when there are no companies left? This shouldn't be that controversial, economic philosophies aside.

I realize the bankers in the room are bored now that rates have started to go up and don't have any remotely useful value to add, but please don't go hype a bunch of CFOs up with your inversion dog and pony show.

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Aug 26, 2014
jankynoname:

This is a good description. I didn't learn anything new here, but others might. Global vs. territorial taxation will certainly be an important topic whenever we have a congress that is remotely capable of discussing comprehensive tax reform without reverting to politardism. Until then, we need to stop the bleeding and block companies and their sponsors from fleeing Merica. Near term this is a tax issue. Long-term, this is about jobs, GDP, allocation of strategic resources, etc. Congress as usual is asleep at the wheel.

Do you guys really want to be paying fuck-high individual income taxes in 5 years when there are no companies left? This shouldn't be that controversial, economic philosophies aside.

I realize the bankers in the room are bored now that rates have started to go up and don't have any remotely useful value to add, but please don't go hype a bunch of CFOs up with your inversion dog and pony show.

Mmhmm. So your initial claim that "soon the U.S. will have no corporate tax revenue" was made with full knowledge that, even post-inversion, companies continue to pay U.S. corporate taxes on domestic income? I have my doubts, though I don't care to argue this point.

As for "fuck-high" individual income tax rates "when there are no companies left" (I have no idea what that means), I offer you the following chart:

Corporate taxes account for 10% of income tax receipts, of which only a fraction represents U.S. taxes levied on foreign income. A congressional estimate of the effect of recent proposals to prevent or curtail tax inversions put the savings at ~$20bn over 10 years. In other words, of the $273bn in corporate tax revenue in FY2013, ~$2bn would be lost from failing to prevent inversions.

Of course revising the tax code to make all foreign income untaxed by the IRS would be more costly, but it would also lead to the repatriation of hundreds of billions of deposits held offshore by U.S.-domiciled companies (Apple, most notoriously). No matter the outcome, the ill-effects are limited at best, and likely to increase domestic investment. Consider me unconcerned about "fuck-high" individual taxes.

More importantly, if the cost of eliminating a ridiculous corporate tax policy and curtailing a double-tax is paying greater individual / consumption rates, I am similarly supportive.

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Aug 26, 2014
NorthSider:

More importantly, if the cost of eliminating a ridiculous corporate tax policy and curtailing a double-tax is paying greater individual / consumption rates, I am similarly supportive.

Alas, another Warren Buffett who wants to pay higher taxes. You must really hate yourself. Now maybe the hardcore conservatives itt will have another target to pick on.

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Aug 26, 2014

Mmm... data. I read through the $20Bn lost revenue study you're citing. The problem is it basically looks at things statically, and does not project much growth in the rate of corporate inversions. If the acceleration in size/number of inversions we're now seeing continues, I think this has the potential to make a meaningful dent in total tax revenue. Just consider where the growth is in most of these businesses. It's not in the U.S. but in EMEA, Latam, Asia etc. If the government does not capture some of that growth then the budget situation is likely to be more dire in 10 years than is already projected.

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Aug 26, 2014
jankynoname:

Mmm... data. I read through the $20Bn lost revenue study you're citing. The problem is it basically looks at things statically, and does not project much growth in the rate of corporate inversions. If the acceleration in size/number of inversions we're now seeing continues, I think this has the potential to make a meaningful dent in total tax revenue. Just consider where the growth is in most of these businesses. It's not in the U.S. but in EMEA, Latam, Asia etc. If the government does not capture some of that growth then the budget situation is likely to be more dire in 10 years than is already projected.

Do you realize how obtuse you're being here? Instead of addressing the crux of the argument, you're nitpicking at the details. Suppose we took 10x the $20bn estimate, we're still talking about less than 10% of corporate tax receipts, which are themselves 10% of federal tax revenue. It doesn't move the needle, it's just a convenient scapegoat to side-step the principle of debate.

Alas, another Warren Buffett who wants to pay higher taxes. You must really hate yourself. Now maybe the hardcore conservatives itt will have another target to pick on.

Really?

1) I wasn't suggesting they pay taxes to the foreign countries, but rather pay the individual income tax rates suggested by foreign countries to the U.S. govt. E.g. if top income tax rate in Ireland is 41% than they should pay that without any deductions. The goal here is to avoid a race to the bottom in terms of corporate tax rates, in which case everyone should just go to the Bahamas which levies a 0% corporate tax rate and has nice beaches.

Ignoring the general stupidity of the idea (why should executives working at internationally domiciled companies pay higher rates into the same tax system?), it's easily circumvented by incorporating in countries with both low corporate and personal income taxes (say, Switzerland).

2) I do not hold this position. I'm talking about major shareholders, execs, and PE sponsors pushing for inversions, not Indian call center reps.

Shareholders are the people calling for such moves (and why shouldn't they?!), it's completely unclear why the identity of the shareholder (PE firm or otherwise) should affect tax treatment. As is it unclear why an SVP should be punished for the decisions of the shareholder, or why the Sr. Manager should be unaffected while his boss' rate is doubled.

3) They should be paying the difference between U.S. rate and foreign rate to the U.S. to the extent their business were built on the back of American ingenuity, prosperity and resources.

What a wonderful law this would be: "Should it be so that your business is 'built on the ingenuity, prosperity and resources of the U.S.', you shall pay the greater of..."

And, finally, you've continued to avoid answering why the U.S. should be entitled to tax the foreign income of its companies, while the majority of the developed world operates otherwise.

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Aug 26, 2014

...you do realize these companies will continue to pay US corporate taxes on their domestic operations. Uniformed and arrogant is an awful combination.

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Aug 26, 2014
Mike Bolton:

...you do realize these companies will continue to pay US corporate taxes on their domestic operations. Uniformed and arrogant is an awful combination.

Yes, I do realize this. As I have stated no less than four times already I understand how the current tax regime works.

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Aug 26, 2014

You've stated, but in no way demonstrated, that you understand.

"Do you guys really want to be paying fuck-high individual income taxes in 5 years when there are no companies left? This shouldn't be that controversial, economic philosophies aside."

Just take a lap, you are either an insufferable blowhard or a great troll.

    • 1
Sep 1, 2014

Despite your 'understanding' of the current tax regime, you keep failing to acknowledge the US Treasury is never going to recognize any incremental revenue on foreign income whether the companies remain incorporated in America or relocate overseas.

At the end of the day, the only difference will be the size of deferred tax liabilities on the balance sheet.

Aug 26, 2014
NorthSider:

If the principals and top shareholders of these inverted companies want to get the tax benefit on the corporate side, they should be willing to pay the higher individual income tax rate. Take it all or nothing.

I've broken this section out because it is specifically and quite hilariously ludicrous.

1) Can we just note the fact that, despite your overarching complaint that corporations / people are taking measures to avoid paying U.S. taxes, you're suggesting that the officers of inverted companies should pay foreign taxes, in lieu of U.S. taxes. What's particularly illuminating about this observation is that it highlights your true policy goal: to take money away from those you perceive to be "too rich", rather than your putative goal of "giving to the poor". You'd rather executives be taxed at a higher rate by a foreign country (to the chagrin of U.S. tax revenue) than have their tax dollars benefit the poor in the U.S. Moreover, I suspect if corporations began redomiciling in, say, Switzerland, where personal income tax rates are lower than those in the U.S., you would recant this position in favor of higher rates in the U.S. Your argument has nothing to do with principle ("take it all or nothing"), and everything to do with your personal vendetta against corporations / the wealthy (which you seem to treat as a common enemy)

2) Let's also appreciate how backwards the world would be if, say, AT&T call center representatives in Bangalore had to pay U.S. income taxes on their earnings because AT&T is domiciled in the U.S. You can't possibly hold this position.

3) As for "top shareholders", they obviously already are subject to foreign tax regimes on foreign investment income. Yet another irrelevant concern.

---

Once again, I suggest you spend some time reading and considering your point of view before offering it on a public forum.

Apologies if I'm not being clear... trying to multitask today:

1) I wasn't suggesting they pay taxes to the foreign countries, but rather pay the individual income tax rates suggested by foreign countries to the U.S. govt. E.g. if top income tax rate in Ireland is 41% than they should pay that without any deductions. The goal here is to avoid a race to the bottom in terms of corporate tax rates, in which case everyone should just go to the Bahamas which levies a 0% corporate tax rate and has nice beaches.

2) I do not hold this position. I'm talking about major shareholders, execs, and PE sponsors pushing for inversions, not Indian call center reps.

3) They should be paying the difference between U.S. rate and foreign rate to the U.S. to the extent their business were built on the back of American ingenuity, prosperity and resources.

    • 2
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Aug 25, 2014

From my understanding it was stated that if BK buys Tim Hortons, they would still operate as two separate restaurants both operated out of Canada.

Dec 21, 2014

delete

Aug 25, 2014

As much as the liberal media would like you to think, this would barely help them on the tax side and the actual "moving the domicile to Canada" has more to do with placating the Canadian government into letting the deal go through.

Aug 26, 2014

Gotta love how Canada is now more business friendly than Amerika. I fully support any company working to minimize the criminal theft foisted upon it by this government.

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Aug 26, 2014

Yah, the US should become even more unfriendly to business. That makes sense.

Corporate taxes are bullshit anyway. Simply a pass through to consumers. The prols cheap for corporate taxes, only to see the cost come out of their pocket.

God bless BK for doing what is best for its shareholders. Any company paying more in taxes out of some lame ass patriotism is doing a disservice to its investors.

Masters in Finance HQ - The #1 site for everything related to the MSF degree!
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    • 1
Aug 26, 2014
TNA:

Yah, the US should become even more unfriendly to business. That makes sense.

Corporate taxes are bullshit anyway. Simply a pass through to consumers. The prols cheap for corporate taxes, only to see the cost come out of their pocket.

God bless BK for doing what is best for its shareholders. Any company paying more in taxes out of some lame ass patriotism is doing a disservice to its investors.

[ ] post is logical and well reasoned
[ ] post applies objective/unbiased insights
[x] troll post - verified

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Aug 26, 2014
jankynoname:
TNA:

Yah, the US should become even more unfriendly to business. That makes sense.

Corporate taxes are bullshit anyway. Simply a pass through to consumers. The prols cheap for corporate taxes, only to see the cost come out of their pocket.

God bless BK for doing what is best for its shareholders. Any company paying more in taxes out of some lame ass patriotism is doing a disservice to its investors.

[ ] post is logical and well reasoned

[ ] post applies objective/unbiased insights

[x] troll post - verified

Yah, wonderful argument. Taxes are part of the overall cost of a good or service. It impacts the cost of an item and is pass through to consumers or offset by lower wages/employment.

Furthermore, the US has the highest corporate tax rate and causes this. A company is a collection of investors capital seeking to maximize their return. It doesn't have patriotism. Furthermore, we operate in a global environment. The US sells it's goods overseas and we buy from overseas companies. If our laws or taxes are a detriment, it dictates companies will relocate. Consumers do the same thing by buying online, waiting for tax holidays or moving to lower taxed states.

I think you need to read up on the subject a little more.

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MSFHQ

Aug 26, 2014
TNA:

I think you need to read up on the subject a little more.

Too late @"TNA"... this guy has eaten up everything the liberal media machine has thrown at him.

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Aug 26, 2014

idk how canadians will react to having their biggest pride taken under American control again.

Aug 26, 2014
flourishingpower:

idk how canadians will react to having their biggest pride taken under American control again.

The 3G guys are primarily Brazilian so national pride isn't being taken over by Americans but, gasp, Latinos.

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Aug 26, 2014

If the U.S. is so uncompetitive, why are the ROICs for U.S. businesses consistently and materially higher than for companies in other countries? That has always puzzled me... oh, we can't afford this harsh U.S. tax regime, and then you check out the P&L and see these whiners are some of the most profitable businesses in the world. Again, if they don't want to operate in the U.S., be my guest and leave... otherwise they need to play by the same rules as Joe Entrepreneur.

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Aug 26, 2014
jankynoname:

If the U.S. is so uncompetitive, why are the ROICs for U.S. businesses consistently and materially higher than for companies in other countries? That has always puzzled me... oh, we can't afford this harsh U.S. tax regime, and then you check out the P&L and see these whiners are some of the most profitable businesses in the world. Again, if they don't want to operate in the U.S., be my guest and leave... otherwise they need to play by the same rules as Joe Entrepreneur.

They are leaving and in case you hadn't noticed, we already live in a globalized economy. So now you are attempting to argue that the U.S. has the right to tax profits earned on goods and services rendered in another country, using another country's infrastructure, and subject to that country's taxes?

There is a reason no other developed nation is doing this. There is nothing illegal about these inversions, nor should there be.

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Aug 26, 2014
jankynoname:

If the U.S. is so uncompetitive, why are the ROICs for U.S. businesses consistently and materially higher than for companies in other countries? That has always puzzled me... oh, we can't afford this harsh U.S. tax regime, and then you check out the P&L and see these whiners are some of the most profitable businesses in the world. Again, if they don't want to operate in the U.S., be my guest and leave... otherwise they need to play by the same rules as Joe Entrepreneur.

this is 100% a political problem. blame the fucking politicans that made things so fucking corrupt and complicated that it's worthwhile to pay a bunch of lawyers and accountants to find loopholes instead of investing in their business. corporations have a fiduciary duty to their shareholders and they would be failing that by not pursuing this (in some cases)

Aug 26, 2014
jankynoname:

If the U.S. is so uncompetitive, why are the ROICs for U.S. businesses consistently and materially higher than for companies in other countries? That has always puzzled me... oh, we can't afford this harsh U.S. tax regime, and then you check out the P&L and see these whiners are some of the most profitable businesses in the world. Again, if they don't want to operate in the U.S., be my guest and leave... otherwise they need to play by the same rules as Joe Entrepreneur.

It's not as simple as you want to make it. Any company doing business in the US will still pay US taxes on US profit. They're too high, complicated yada yada yada, that's another discussion. The reason companies move offshore (inversion) is because the US also taxes non domestically produced profit unlike nearly every other country in the world. If the US doesn't want companies to move offshore then create a competitive tax code. The worlds a free market. A company's highest priority is to legally produce the highest return to shareholders. If you can trim a non trivial amount of tax cost by legally relocating and do not do it its irresponsible corporate management and governance. Pure and simple. This isn't to be blamed on a company or investors, it should be blamed on the dumbfucks in DC who can't get their heads out of their collective asses.

And it's not like BK is moving to North Korea. It's Canada for the love of god.

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Aug 26, 2014

I appreciate your response. I understand the tax regime and that they presently need to pay U.S. tax rates on foreign earnings. I think that is justified because the U.S. has done a lot of protect infant industries, get businesses off the ground etc., so this is almost like dividending a portion of subsidiary income back to the States in recognition for its services (again infrastructure, education, contract/IP law, banking etc.).

To be clear I think the U.S. needs to go through some major comprehensive tax reform to make these things simpler, and maybe also cheaper (i'd leave that to policymakers). But letting a bunch of companies slide through the cracks and end up shifting huge economic upside to other countries is messed up imo.

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Aug 26, 2014
jankynoname:

I appreciate your response. I understand the tax regime and that they presently need to pay U.S. tax rates on foreign earnings. I think that is justified because the U.S. has done a lot of protect infant industries, get businesses off the ground etc., so this is almost like dividending a portion of subsidiary income back to the States in recognition for its services (again infrastructure, education, contract/IP law, banking etc.).

To be clear I think the U.S. needs to go through some major comprehensive tax reform to make these things simpler, and maybe also cheaper (i'd leave that to policymakers). But letting a bunch of companies slide through the cracks and end up shifting huge economic upside to other countries is messed up imo.

These companies are "slipping through the cracks" because the US tax system isn't competitive in the slightest. Taxing companies on their foreign subsidiaries earnings is ridiculous as they are then being taxed by 2 countries. Charge a competitive corporate tax rate on earnings solely from within your own country, then there wont be any companies pursuing inversions. It's quite simple.

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Aug 26, 2014

But a 35% dividend because the US has incubated infant industries? That's a bit steep (and I know there are deductions out the bum for it so no one really pays 35%). And if a company is using the infrastructure in another country they're paying the taxes there already and not benefiting from construction on I-95. And if you extrapolate it to the absurd, should we be paying a tax to the UK because they initiated settlement, infrastructure and common law in the US even though they haven't done much since then?

But theoretical talk doesn't matter. In practice a company can offshore itself because there are more attractive tax jurisdictions and almost no other country taxes offshore income. Just because we're current the only 800 lb gorilla in the world our government assumes that we can and should do it. It's anti-competitive to us in a world that is shifting away from a single superpower, militarily and economically. I don't think we're in a death spiral and in a generation we're going to have a quality of life like Mali, but if we have continue our tax policies with the belief that these companies owe something to the US because we've done something to benefit them in the past, we'll simply continue to lose corporate headquarters to other countries. In the long term that's just not good. It also has the unintended consequence of companies not repatriating profits from abroad because they will be taxed. Apple is a perfect example. They had something like $90B of offshore profits that they didn't want to repatriate because it would have been taxed. They could have used that money to reinvest in things onshore or pay a domestic dividend (yes, they were able to borrow anyway to do these things but not everyone has $90B in cash and is Apple where those options are open) but it's idiotic that companies don't want to even bring profits back to the US for fear of taxation. As other countries rise and the world has become a more open and free market, it just hurts us in both the short and long term.

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Aug 26, 2014
Dingdong08:

But a 35% dividend because the US has incubated infant industries? That's a bit steep (and I know there are deductions out the bum for it so no one really pays 35%). And if a company is using the infrastructure in another country they're paying the taxes there already and not benefiting from construction on I-95. And if you extrapolate it to the absurd, should we be paying a tax to the UK because they initiated settlement, infrastructure and common law in the US even though they haven't done much since then?

But theoretical talk doesn't matter. In practice a company can offshore itself because there are more attractive tax jurisdictions and almost no other country taxes offshore income. Just because we're current the only 800 lb gorilla in the world our government assumes that we can and should do it. It's anti-competitive to us in a world that is shifting away from a single superpower, militarily and economically. I don't think we're in a death spiral and in a generation we're going to have a quality of life like Mali, but if we have continue our tax policies with the belief that these companies owe something to the US because we've done something to benefit them in the past, we'll simply continue to lose corporate headquarters to other countries. In the long term that's just not good. It also has the unintended consequence of companies not repatriating profits from abroad because they will be taxed. Apple is a perfect example. They had something like $90B of offshore profits that they didn't want to repatriate because it would have been taxed. They could have used that money to reinvest in things onshore or pay a domestic dividend (yes, they were able to borrow anyway to do these things but not everyone has $90B in cash and is Apple where those options are open) but it's idiotic that companies don't want to even bring profits back to the US for fear of taxation. As other countries rise and the world has become a more open and free market, it just hurts us in both the short and long term.

+1

Aug 26, 2014
jankynoname:

I appreciate your response. I understand the tax regime and that they presently need to pay U.S. tax rates on foreign earnings. I think that is justified because the U.S. has done a lot of protect infant industries, get businesses off the ground etc., so this is almost like dividending a portion of subsidiary income back to the States in recognition for its services (again infrastructure, education, contract/IP law, banking etc.).

To be clear I think the U.S. needs to go through some major comprehensive tax reform to make these things simpler, and maybe also cheaper (i'd leave that to policymakers). But letting a bunch of companies slide through the cracks and end up shifting huge economic upside to other countries is messed up imo.

Per usual, when confronted with facts you didn't appreciate going in, you slowly retreat from your initial nonsense ("pretty soon the U.S. won't have any corporate tax revenue").

Your impenetrable assessment that the U.S. government has somehow incubated the success of U.S.-domiciled fast food chains in foreign countries (and thus is entitled to tax income therein received), runs contrary the global standard of corporate tax regimes. Nevermind that it is entirely unclear why the U.S. should be so deserving of tax receipts on foreign profits while, say, the U.K. is not. This argument makes no sense and is frankly irrelevant.

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Aug 26, 2014

gotta love that piece of shit Buffett financing this

Aug 26, 2014

Liberals have never met a tax they don't like. I'm sure they'd be calling Washington unpatriotic back in the day also.

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Aug 26, 2014

Fiscal conservatism; now apparently a "liberal" idea.

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Aug 26, 2014

Buffet is financing 25%, they are moving burger king headquarters to Oakville Canada to lower taxes. Burger King is trying to compete better in the breakfast space, Tim Hortons is king in breakfast in Canada. Tim Hortons was looking for a better international strategy. 3G will own 51%. Burger King and Tim Hortons will remain independent names.

I wish i could shove my dick so far up your dick that it creates a gaping vagina, because that's who you are.
Just tell them that you're a ginormous douche-canoe with a gaping vagina. They'll understand.

Aug 26, 2014

Jesus Christ, the ultimate irony here is that these guys already have the same fucking tax rate. What a shit show.

Aug 26, 2014

man i've never gotten so much monkey shit in one day... I guess that's an accomplishment.

Maybe I can derail this thread with my signature '80% incremental tax on incomes over $10mm' proposal, and accrue some more.

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Aug 26, 2014

Because you have a history of sounding like a know-it-all, while not knowing anything at all.

Aug 26, 2014

I think this is a great deal and 3G has a pretty impressive track record of jacking profit margins through the roof. I think the relocation of BK to Ontario has more to do with negotiations than BK fleeing taxes in the states, although that does play into it. Nabooru made a good comment that it may be about pleasing the regulators. A Liberal government was just re-elected in Ontario and they promised big incentives to companies bringing jobs to Ontario so this might also play into it

Aug 26, 2014

Nothing more patriotic than fueling the tax coffers of the government so they can spy on their citizens, provide military equipment to cops, kill people with drones all over the world, fail to secure our borders, and other wonderfully patriotic things it does in the reg.

Evil companies not paying their fair share.

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Aug 26, 2014

I am not familar with the financials, but this sounds like a win.
As for US corporate taxation, it is broken. The double taxing of income earned abroad is nonsense... but so is the level of tax loopholes, incentives and the like that allow highly profitable companies to pay little to no tax in a particular year.
The corporate and income taxes in the US is complete f*king corruption. It is designed to obscure who pays what and why. We have an entire industry dedicated to accounting for and avoiding paying taxes. I would be thrilled with a system that either eliminates or phases out deductions, or even as extreme as no income tax at all and only a federal sales tax. Only pay based on consumption instead of income, this way you can tax all of the money that is borrowed before it is earned... but clearly I've stepped outside the bounds of the post.

Doog37

Aug 26, 2014

Anyways I've gotta run, but allow me to turn it over to our fearless leader for concluding remarks. Sorry to OP for hijacking your thread.

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Aug 27, 2014

HMMM....I came here to discuss the what the new menu should include. Guess I'm in the wrong thread.

Dec 21, 2014

delete

Aug 27, 2014

I don't know how nobody has put this in regards to @"jankynoname"

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Aug 27, 2014

appreciate that. very clever.

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Aug 27, 2014

I think the solution is very simple. There should be a VAT charged only to retail companies that are subsidiaries of foreign corporations. Either you pay us 25% of your global net income or 5% of your gross US revenue. The cost should be borne by the companies subject to the charge, and they should be required to advertise all prices inclusive of VAT so consumers can make a fair comparison. (The cost will be partially borne by consumers, sure, but there will also be a huge transfer from foreign companies to domestic firms)

I have nothing against foreign companies, but domestic firms should have clear advantages in selling to US consumers if they pay 25% of their global income (net if local taxes) as tax.

Meanwhile we should also have a foreign lobbying transfer tax. Foreign companies that wish to hire lobbyists should be required to pay 50% as tax. I am fine with people trying to not pay US taxes and I am fine with people trying to influence our government, but I am not fine with doing both at the same time.

Aug 27, 2014

The Harper government lowered corporate tax rates to make Canada a more competitive place to do business. The rational response would be to do the same with the US tax code, not scream about "economic patriotism."

Metal. Music. Life. www.headofmetal.com

Aug 27, 2014

The tax advantages stemming from this deal won't be that great...not enough to warrant it anyways, so don't think we can really call this to be in the same camp as other inversion deals.

Anyways, the deal makes sense. Tim & BK both love to own as few stores as possible, opting to franchise a larger percentage than is common in the industry...making them a good fit business model wise. Plus Tim Hortons has A LOT of room for growth and can do in markets BK already knows well.

Doubt they'll combine the entities though...can't see TH coffee in BK haha

Aug 27, 2014

the stupidity of some of the comments here (not you dingdong & northsider) makes me wanna

Aug 27, 2014

I for one am pretty proud of what I was able to accomplish here...hell even I don't believe half the shit I posted. Some of these guys I only see posting when there is a super politically charged debate, e.g. @"NorthSider". You guys in general are probably a bit too conservative to be considered objective on these kinds of issues, but I think that's par for the course in finance.

Aug 27, 2014
jankynoname:

I for one am pretty proud of what I was able to accomplish here...hell even I don't believe half the shit I posted.

... ??

Some of these guys I only see posting when there is a super politically charged debate, e.g. @NorthSider.

3,600 "exclusively politically charged" posts and counting!

You guys in general are probably a bit too conservative to be considered objective on these kinds of issues, but I think that's par for the course in finance.

What could possibly be the meaning of "objective" in this context? We're debating a matter of policy; neither I nor you can offer "objective" (whatever that would look like) suggestions. And FWIW, I'm not conservative. In fact, I'd wager you'd find me far more liberal than you are, granted I haven't heard any of your stances outside (your ludicrous) tax suggestions.

Aug 27, 2014

Well I'm all for Burger King workers ejaculating into chicken sandwiches, if that's what you're asking...

Aug 27, 2014

I'm not particularly conservative and in most finance circles I'd practically be considered a socialist. I'm much more pragmatic when it comes to issues. The US tax system, corporate and personal, is probably the worst in the western, civilized, free world. It drives corporations offshore. It prevents corps from repatriating money. It keeps foreign investors from investing. A few years ago we were raising money and went down the road with a very wealthy South American individual. He could, and did, stroke 9 figure checks. He was very hesitant to invest in the US not because he didn't want to pay taxes on profit here but because investing in one US thing basically gave the IRS carte blanche to look into everything he did anywhere in the world under the guise of figuring out if he was avoiding US taxes. And if they determined he did they could get foreign banks and government to lock up his assets. The over reach and utter gall of the US tax system is disgusting.

Aug 27, 2014

Canada has actually been doing remarkably well with regards to corporate taxes and being business friendly. Many reports have put them as #1 over the past few years.

KPMG said so this year: http://www.kpmg.com/ca/en/services/tax/focus-on-ta...

1. Canada
2. UK
3. Mexico
4. Netherlands
5. USA

Aug 27, 2014

The fact that they are avoiding the US tax system makes it a great deal.

Aug 28, 2014

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Aug 31, 2014
Oct 14, 2014