A Message to the Apple Community in Europe - <AUTHOR> http://www.apple.com/ie/customer-letter/ <comment><USER2> People filing their own tax returns: "This is pretty complicated. Maybe I should hire an accountant or something"

People commenting on a case involving international tax law and how it applies to a mega corporation: "I got this - I'm gonna tell everyone else what the fair and legal result of this case should be"

OTOH, I'm getting a bit tired of these PR pieces that pretend that their company is all about uplifting communities and helping people. I've got nothing against free-market capitalism -- it seems to be working out more or less OK compared to some other economic systems we've tried -- but it seems pointless to have to always pretend that you're not playing the game in order to make profits. A "yes, this was a loophole that we found that allowed us to not pay much tax, but that doesn't give anyone the right to close it retrospectively, and we'll be seeing the EU in court" would have been a nicer statement to read from them.

<comment><USER3> I thought it was rather barefaced in the article that moments after crediting itself for lifting all those poor citizens of Cork out of poverty by giving them jobs (there's quite the "you should've seen the place before we came along, terrible, terrible" vibe to the first two paragraphs) it then goes on to deride the people it employs as being worthless by saying that of course virtually all the real value is created in California...

Sure, it's R&D is in California. But R&D is only 7% of its expenditure. The other 93% is necessary to bring in the revenue, so it very much part of the value.

<comment><USER4> The sad thing is, it's kinda true. Not just Apple, and not just Cork, but overall the 'sweetheart' deals for companies bringing a lot of employment to the country, have helped. They're helping us find jobs rather than directly putting coin in the state purse, but I'm okay with that.

This is a country where, in the 70s & 80s, finding a job meant moving to the UK. Now, pretty much everyone I know works for one multinational or another. And the multinationals all came here for the same reason.

</comment></comment></comment><comment><USER5> The most specific and IMHO damming allegation was _how_ they avoided paying tax.

From the EU press release:

        [Ireland] endorsed a split of the profits for tax purposes in Ireland: Under
        the agreed method, most profits were internally allocated away from Ireland
        to a "head office" within Apple Sales International. This "head office" was
        not based in any country and did not have any employees or own premises.
        [...]
        The remaining vast majority of profits were allocated to the "head office",
        where they remained untaxed [...] an effective tax rate of about 0.05% on
        its overall annual profits.

So, at the advice of Ireland, Apple was able to attribute sales to 'Apple Sales International', which was not based in any country and thus was not subject to tax.

<comment><USER6> And to use Cook's words "A company's profits should be taxed in the country where the value is created." By this logic maybe the EU should get only VAT, which is paid by Apple's customers and not by Apple, but the US is left without a huge amount of tax money.

<comment><USER7> That statement itself means very little. I would argue the value is created where thousands of workers turn designs into millions of individual devices; Tim Cook might argue value is created where slapping an Apple logo on the device transforms it from a regular gadget into a luxury status symbol. Either way the issue here isn't where Apple should pay tax, but that they should be taxed fairly. There are many international tax treaties to prevent double taxation, Apple simply need to pay tax like (most) everyone else.

<comment><USER8> You see, if there's no clear answer to where the value is created, then there's no clear answer to where the profits are taxed! So it kinda clips through the cracks. Whoops!

<comment><USER9> The value is "created" where the sale is made. Until money changes hands, there is no concrete value.

<comment><USER10> I think this is the best way to tax corporations. Corporations can move around where they produce goods, but it's much harder to move where they sell them.

</comment></comment></comment></comment></comment></comment><comment><USER11> I don't really get what Apple is trying to achieve with this letter. Looking at my (continental) European colleagues, it comes across as aggressive bullying by a U.S. company and clearly harms public opinion of Apple, which cannot be a good thing for a company that sells consumer products. Maybe it looks differently from the Irish perspective, but obviously Ireland is a tiny market compared to France / Germany / etc., which are all countries where U.S. companies' (legal!) tax maneuvers aren't looked kindly at and where such a letter can only do more harm than good. People don't like the European Commission, but they like "lecturing from the Americans" even less.

In the end, this matter is a very complex legal question (1. were the Irish tax deals actually "deals" or just the day-to-day application of the Irish tax code?; 2. if they were "deals", were they illegal deals under EU rules against state support?). It is going to be answered by the European Court, which I guess (or at least hope) will not make its decision based on an "open letter" posted on the Internet.

<comment><USER12> I reckon the letter is intended to maintain support in Ireland rather than the EU, which is a lost causes. Given the rise of EU scepticism and Brexit (remembering the UK and Ireland are extremely close) if Apple can maintain support in Ireland, Ireland will continue to push back strongly and might be somewhat successful.

Of course it could also back fire with the EU (particularly Germany) playing hard ball with both Ireland and the Brexit negotiations simultaneously and any negative effects on the UK economy scaring Ireland into compliance.

<comment><USER13> Irish sentiment is and remains vastly more pro-EU than it ever was in the UK.

That said this is a very cynical ploy by Apple.

<comment><USER14> > Irish sentiment is and remains vastly more pro-EU than it ever was in the > UK.

Then why on earth would Apple think Ireland will side with them rather than the EU? If anything, the EU holds all the cards here since Ireland will have to negotiate with the EU post-Brexit, and who knows if Apple taxes will be a bargaining chip?

<comment><USER12> Why would Ireland need to negotiate with the EU?

<comment><USER15> Although I think not what was being referred to, the UK and Ireland do have a more porous border than most EU states do with their non-EU neighbours.

</comment></comment></comment></comment></comment></comment><comment><USER16> This is getting interesting. One of the world's biggest companies is playing the emotions of the citizens of a country, and essentially telling them to distance themselves from the EU.

"This would strike a devastating blow to the sovereignty of EU member states over their own tax matters"

Maybe this doesn't look _that_ serious to non-EU citizens but given what's happening in Europe in general (nationalist parties on the rise, etc.), I'd be very careful with this approach.

<comment><USER17> I was thinking the same thing. This letter by Apple appeals to the same feelings that were used to make Brexit happen.

<comment><USER18> It's not an appeal to feelings, it's a statement of fact.

The EU was never meant to control member state's tax policies. That's exactly what they are now trying to do. Regardless of whether you feel they're justified or not, Apple's point is sound: it _is_ a loss of sovereignty.

</comment></comment></comment><comment><USER19> I lost a very large amount of respect for Tim Cook reading that message. The statement:

> A company's profits should be taxed in the country where the value is > created. Apple, Ireland and the United States all agree on this principle.

is patently false given the Double Dutch Irish Sandwich structure of Apple tax reporting. This is not a coy avoidance the truth, this is a blatant lie.

No response, short of a link to an album of photos from the large and gleaming worldwide R&D centre that Apple presumably operates in Curaçao is acceptable.

<comment><USER13> Nah.. everyone knows very little value is created in California or Shenzhen. It's all done in a few small offices in Ireland, dontchaknow.

<comment><USER19> Irony aside, I have argued in the past, and I will argue that some innovations from Google/Amazon/Facebook/Apple (GAFA) are not exclusively done in Silicon Valley (or Shenzhen, when it comes to hardware).

I have seen a team of engineers, all trained for free by a French university, have a meeting, in French, with senior executive of a French group (from the same university) about a software tool they wanted to implement; the suggestion that came out was based on algorithms developed by engineers and scientists working within a joint program between a large state-owned industrial group and French universities.

I would add that said alumni all were generously paid during their study, but that would identify the university. Not the program, or the algorithm, though. And that's the rub: it happens all the time.

Added value to GAFA: billions. Money that the French government put into the program: dozens of million directly; billions if you include maintaining generations of engineers up to date. Money that the French government is going to get from that: zilch.

And all the engineers, senior of not, are very proud to have benefited from those program. This is their identity, literally: they introduce themselves using the common formula First name, Last name, University, Graduation year.

To have those executive remain silent internally is sickening.

</comment></comment></comment><comment> k-mcgrady I think generally Apple has been a pretty socially responsible company, more so than a lot of other tech companies. I also really admire their stance on privacy. They get no sympathy from me here though and this 'message' makes them look worse. When you have $200bn in cash reserves - literally $200bn you have no idea what to do with - and you're complaining about paying $14bn in back taxes you just make yourself look bad. The excuse that you brought jobs to a struggling economy also doesn't help you. You didn't look at Ireland and say 'those poor unemployed people, lets open an office there', you said 'they really need jobs, we can probably negotiate a good deal'.

<comment><USER20> I would agree with you if it were really a case of Apple dodging tax by (for example) lying about their revenues to reduce their tax bill.

Except it's not. Apple paid all the tax Ireland asked for. The problem is the EU are saying _Ireland should have different tax laws_ and therefore Apple should now pay Ireland retrospective taxes based on what the UN thinks Ireland's tax law _should have been in the past._

The problem with that should be mind-numbingly self-evident.

<comment> k-mcgrady 1\. It's the EU, not the UN.

2\. My understanding is that Ireland's tax laws should meet a certain EU standard. Apple was meeting Ireland's laws but Ireland was not meeting the EU's and thus Apple wasn't paying the correct amount of tax. So the laws have always been in place, they just weren't being followed correctly by Ireland or by Apple.

<comment><USER20> 1\. Fixed, oops!

2\. That sounds like fault lies with Ireland, not Apple. Or perhaps with the EU for failing to enforce their own damn rules.

<comment> k-mcgrady >> "That sounds like fault lies with Ireland, not Apple. Or perhaps with the EU for failing to enforce their own damn rules."

This decision is the EU enforcing the laws though. And I think the fault does lie with Ireland - but nobody is saying the fault lies with Apple. That's why they're not being fined. They're just being told to pay money they have always owed, money which was never theirs. I can see it from both sides though. Why should Apple be 'punished' if they were told they were paying the right amount? On the other hand if my accountant screws up my taxes and I pay too little I have to pay it back eventually.

<comment><USER20> >> "They're just being told to pay money they have always owed"

...to an entity that repeatedly insists they're not owed it.

<comment> k-mcgrady True but Ireland has an interest in fighting this too. There are potentially thousands of jobs on the line plus a lot of future investment. I don't think this will cause any companies to leave Ireland as there is now going to be nowhere else in the EU they can run this tax deal but it takes away an edge they have on investment over other major European cities.

</comment></comment></comment></comment></comment></comment></comment><comment><USER21> "Taxes for multinational companies are complex, yet a fundamental principle is recognized around the world: A company's profits should be taxed in the country where the value is created. Apple, Ireland and the United States all agree on this principle. In Apple's case, nearly all of our research and development takes place in California, so the vast majority of our profits are taxed in the United States."

So is R&D the only part of the company they believe creates any value? Why operate in Ireland at all if so? Should just outsource it all...

Of course they know better. The value is right there in the first paragraph:

"Thirty-six years ago, long before introducing iPhone, iPod or even the Mac, Steve Jobs established Apple's first operations in Europe. At the time, the company knew that in order to serve customers in Europe, it would need a base there."

<comment><USER22> Yup. The question is -- where do you create "value", only in R&D or also through the manufacturing and distribution chain?

If only R&D created taxable value, there would be no need to tax anyone after the research stage. Of course that's not the case (and it's actually the opposite of what you want, as a society). This is a very weak argument; if that's all they have, they're going to lose any appeal.

</comment></comment><comment><USER23> A message to Apple from anyone who doesn't have rocks in their head:

You shift profits to avoid tax, don't play coy.

The era of tax being optional for multinationals is drawing to a close. You make your profit, you pay for access to the market, no exceptions.

<comment><USER24> Of course they did (the loophole is now closed), but the point here is that this scheme was entirely legal. The EC is now saying that even though it was legal, they owe the tax anyways. That is not how things should work in a system based on the rule of law and fairness.

Imagine for a moment that your own government raised your personal tax rate and said that since they felt the previous tax rate was too low, you also owe taxes from the past.

<comment><USER25> "Member states cannot give tax benefits to selected companies - this is __illegal__ under EU state aid rules," the commissioner said.

"The Commission's investigation concluded that Ireland granted illegal tax benefits to Apple, which enabled it to pay substantially less tax than other businesses over many years."

[http://www.rte.ie/news/2016/0830/812819-apple-tax- ireland/](http://www.rte.ie/news/2016/0830/812819-apple-tax-ireland/)

<comment><USER24> It seems hard to believe that Apple was receiving special treatment when practically every MNC has been using this very same loophole. But at this point it is he said/she said. This loophole is now closed, so the EC pursuing this feels more vindictive than anything (especially since the EU has had it out for US tech companies for awhile now).

<comment><USER26> It's likely that Google, Facebook, Ikea, et al. will receive similar consequences in the near future. Apple is just the first to receive a slap in the wrists. Hopefully this will reach beyond Ireland and similar investigations will be done in Netherlands and Luxemburg.

A lot of Europeans (me included) are not at all happy to see massively profitable companies operating in Europe without paying practically any taxes. This makes it impossible for European companies to compete with them and I'm very glad the authorities are looking to level the playing field and bring in some tax revenue while doing so.

<comment><USER27> I am a Luxembourger and I fully agree that the EU must close these kinds of tax loop holes. In the past my country made a little money out of these tax loop holes, this was immoral money that my country did not even need. Doing this, other European countries lost a lot of tax income. The only ones winning big time in scheme were the international companies abusing the EU and its people.

<comment><USER28> Just out of curiosity, why would tax competition be considered bad? It is generally accepted that monopolies and cartels are bad for the free market, but when it comes to governments and the services they provide, we're completely OK with tax cartels. These EU and OECD tax agreements basically amount to a tax cartel, where governments agree they'll fix their tax rate regardless of the infrastructure and level of services they provide...

<comment><USER29> It is bad because it decorrelates the country you make a profit out of from the country you pay taxes on this profit.

The people paying for your product are able to buy it because they live in a country that provides for them, through added value, jobs, health care, infrastructure and so on. If you want to profit from these people's buying power, then you have to conform to that country's rules of business, that's all.

Apple is _very_ happy to make huge sells of iPhones thoughout France, Germany, Italy and such countries, siphoning money from their people to Ireland, without ever contributing as much into the local economy. They employ a few hundred people in Apple stores and hotlines, but compared to their profit it is just ridiculous.

<comment><USER28> Is that really the case? Apple operates in Ireland and it pays taxes there based on a certain competitive rate it has. If Apple sells phones in certain countries, it has a network of suppliers there and it pays taxes on their business operations there. It seems that you're making the argument that the phones have to be produced in every country where they're sold in order to eliminate trade deficits (the so-called decorrelation of profits and taxes that would result from the importing of a product). But the only way for the other countries to get that tax revenue would be to be competitive enough (through competitive tax rates, availability of talent, infrastructure, legal system, etc.), so that Apple would be incentivized to open offices and move their R&D and pay taxes there. It seems you're arguing that these other countries shouldn't have to compete on these criteria, but should somehow be entitled to that tax revenue or at least to protectionist measures that would make sure that Apple has no incentive to go anywhere else, purely based on the fact that willing buyers purchase Apple's products there. I'm not sure that's a very strong argument because it basically amounts to saying that if you don't force Apple to give some form of a discount to these buyers, they won't be able to buy the product in the future...

<comment><USER30> The thing about transfer pricing is that it makes the "location where value is created" _completely arbitary_. It's not where the R&D is done, it's where the shell company that holds the patents is registered.

Apple subsidiaries in random countries selling phones don't pay taxes because they don't make any profit. They don't make any profit because they're "charged" an amount for the phones (and IP, branding etc) that exactly equals the sales.

</comment></comment></comment></comment></comment></comment></comment></comment></comment></comment><comment><USER31> Oh dear this is pretty mendacious:

" A company's profits should be taxed in the country where the value is created. ... In Apple's case, nearly all of our research and development takes place in California, so the vast majority of our profits are taxed in the United States."

No, I don't think the agreed principle is at all to tax research and development - it is to apply taxes at the point where the transactions take place.

In this case, in Europe. And the European UNION is named that way for a reason; the states have to abide by rules that are designed to protect and enhance the European collective-bargaining position, just as for workers in a labor union. Even so, some states still try to use lax corporate legislation as a competitive edge.

Now they've been caught out.

I'm no fan of retroactive taxation, but there it is - if the tax arrangements are deemed illegal, then the beneficiaries of that are going to be on the hook. Apple's claim that they followed the law may be true to an extent, but the full 'legal tax' situation must obviously include not only the Irish tax rules, but also the European ones, so they appear to have failed in due diligence.

</comment><comment><USER32> > a devastating blow to the sovereignty of EU member states

This is bad, bad PR. Maybe let the EU citizens be the judge of that?

IMHO, it is a huge no-no for a company to make a political statement, especially in a troubled time like now (does Apple have any comments on Brexit, too?).

I think this will deeply hurt the fanboyism.

<comment><USER12> Or it might play well on rising nationalist anti-EU sentiments throughout Europe. The EU has a lot of battles to fight at the moment so Apple might be betting that they back off to an extent. That said I agree it will likely blow up in Apples faces. It strikes me as a line that would play well in the US (replace EU with US and re-read it) that they've not realised won't work over here.

<comment><USER33> Honestly since brexit I've been constantly amazed how little Brits and Americans understand continental Europe's opinion on the EU.

On the continent euro-sceptics operate on the extreme political fringe, they never got into any parliament in numbers and are considered toxic as coalition partners.

The EU won't blow apart, the EU is a fact of life and an economic necessity, Brexit was so shocking because it is indeed unbelievable that anyone would try to quit the EU.

</comment></comment></comment><comment><USER34> Yuck. Old black and white photos, emotional appeal to some sort of corporate heritage. Posturing as some sort of victim. Only thing missing is a tiny violin playing on that webpage.

Apple's been paying virtually no tax for years because it's argued it's legal to do so. Now the EC deems it was illegal. GG WP - you lose. Time to pay up now.

I'm sure due to the amounts involved that this potential event was in someone's "risks" column and hasn't come completely out of the blue for Apple.

<comment><USER35> According to the letter Apple is the largest taxpayer in Ireland, in the United States and in the world, surely that statement is incompatible with the statement that "they've been paying virtually no tax for years". One of these statements must be false.

<comment><USER19> Apple pays VAT, employment tax in Ireland and certainly a couple more. They avoid paying _corporate tax_ by using a Irish sandwich Double Dutch tax structure (where you create subsidiaries of subsidiaries, and pretend all the value creation happened in over-seas territories where corporate tax is negligible).

Apple is probably right in saying that the total of VAT, employee tax, etc. is the largest in Ireland, the US and World: they are the largest company in the world, so that statement should be fairly obvious. If someone who makes 1M$ per year pays 0.5% taxes, he still pays more than someone who pay 20% of their 24k$. That's why this statement is seen as disingenuous: the ratio to your revenue is was matters.

The European Commission, the vast majority of observers and almost all Hacker News members are right in saying that they paid virtually no (0.005%) corporate tax, because that was the point of the statements they made to tax authorities around the world.

On whether what Apple did was legal: the stated that their all their value creation happened in the Dutch Antilles, which is patently false. That is nothing short of lying on your tax form. The Irish government accepted it because they were strong-armed into accepting that or seeing jobs go elsewhere. That type of coercion is also something that this letter lies about.

In the US, John Oliver pretending he is the Head of a Church whose main tenet is his personal enrichment is widely accepted as a legal, and deserving of a tax break; in the EU, such statements are considered disingenuous (that's the fancy word for "bullshit") and treated accordingly.

<comment><USER36> > Apple pays VAT

That is incorrect. Apple doesn't pay VAT, they offset any notional VAT bill against the total of VAT collected from customers and pass-through the residue to the revenue agency.

 _Generally, each such trader in the chain of supply from manufacturer through to retailer charges VAT on his or her sales and is entitled to deduct from this amount the VAT paid on his or her purchases._

[http://www.revenue.ie/en/tax/vat/](http://www.revenue.ie/en/tax/vat/)

The non-corporate end-user is stuck with paying VAT because they're not 'adding value'.

<comment><USER19> You are technically correct, which is the best kind of correct.

However, I'd be surprised if Apple buys enough things in Ireland to offset the sales of iPhones in Europe.

<comment><USER37> Apple is not paying VAT, it's collecting it. VAT is explicitely paid by the end user...

<comment><USER19> The difference between the VAT that Apple collects and the VAT that is reversed to their provide is what is considered paid by Apple — at least, I assume it was in their lawyer's math claiming they pay more taxes than anyone else.

You seem familiar with the principle of VAT. In reality, many companies who practice tax optimisation scheme are happy to play with that notion beyond recognition.

In Europe, Amazon aligns some of its prices to local prices including VAT, but they only collect Luxembourg VAT, pocketing the difference. The tax accountant of any (international) travel agent would be happy to dazzle you with how much money they are making from creative interpretation of international rules on VAT. If a good is not sold, the last buyer still owe the VAT on it, even when they are not a user of that good, end user or otherwise.

VAT is paid by companies: I've had enough issues with my own tax to confirm that you don't need to collect it to owe it to unscrupulous governments.

</comment></comment></comment></comment></comment></comment></comment><comment><USER38> Here is the European Commission's word on the issue: [http://europa.eu/rapid/press- release_IP-16-2923_en.htm](http://europa.eu/rapid/press- release_IP-16-2923_en.htm)

</comment><comment><USER39> True story: in the mid-2000s I was in the audience at an Apple recruiting talk for H1Bs at a European university (including one fairly-well-known then-Apple dev/manager). It didn't go very well: the audience was oblivious and largely uninterested, the Appleers were tetchy, I asked an impertinent question involving HyperCard. At one stage the rambling audience Q&A turned to a long discussion of the hypothetical possibility of Apple opening a European office at some point in the future. Now granted these were SW dev types rather than QAs or whatever, but ... I didn't quite have the heart to tell them about Cork.

I'm not so sure about this bit, but IIRC at this time (and a long time afterwards) Apple wasn't investing much effort in the pretence that Cork was a serious operation, to the extent that the access road to the site wasn't in good repair and hadn't seen attention in ages, possibly since it was built. [EDIT: I am duly corrected on this, see [https://news.ycombinator.com/item?id=12390072](https://news.ycombinator.com/item?id=12390072) below.]

<comment><USER40> To say Apple's Cork presence is just a pretense is largely inaccurate. I've been to the Cork campus numerous times while I worked for the company for seven years (2005-2011). The campus was, and is, still a huge base of operations for Apple. The majority of their AppleCare international support is based there (both support personnel and management/exec), as are many other departments. There are, literally, hundreds of people there from all across Europe who have relocated to Cork.

Beyond the main Holyhill campus, Apple has a large amount of office space within Cork's city centre.

Additionally, Apple also has a pretty big assembly line there. Many of their products have also been (and still are) assembled there. For many of the PowerPC and earlier Intel machines, if the serial number started "CK", it was assembled in Cork (it's been a while since I've memorized Apple's serial number structure, but they used to be much easier to parse).

However, the area of Cork that Apple's campus is located isn't very affluent and suffers like many inner-city boroughs in Ireland and Europe. Ultimately, the state of the roads isn't Apple's responsibility. You'd hope that a company like Apple could lean on the local government to improve it, but Apple wasn't the company it is today, back in the early 2000s. It was getting there, but it was still coming out of the near-bankrupcy 90s.

<comment><USER39> Thanks. I think my anecdote still illustrates how fully removed Cork was from any of the high-value development or R&D work that Apple seems to have been accounting to Ireland though.

<comment><USER40> Definitely agree with you on the development / R&D. Cork is more a logistical base that's more about the day to day workings of the company, as opposed to coming up with the next big thing.

</comment></comment></comment></comment><comment><USER41> > _" As responsible corporate citizens, we are also proud of our contributions > to local economies across Europe, and to communities everywhere. As our > business has grown over the years, we have become the largest taxpayer in > Ireland, the largest taxpayer in the United States, and the largest taxpayer > in the world."_

Nice logical fallacy here, positively reframing / dumbing down a company's obligation to pay taxes in ${countries_of_activity} as _" we have become the largest taxpayer in Ireland"_. That's precisely what Apple is condemned for: for consolidating fiscal activity in a tax haven, Ireland, in order to pay ridiculously-small taxes for Euro zone Apple activity, rather than paying (bigger) taxes in each EU country.

Also, Cook mentions _" 6,000 people across Ireland [...] performing a wide variety of functions as part of Apple's global footprint."_. I have no idea what that number represents, scaled to a multinational like Apple. I'd be curious to know what you think of this number.

<comment><USER42> And even more interesting: what have been the consequences, to employment and otherwise, of Apple avoiding to pay billions in taxes?

</comment></comment><comment><USER43> This "message" is almost as bad as dodging taxes through loopholes.

It reads as the Apple Head of State trying to rally the troops, trying the "foreign aggression because they're so jealous" angle.

</comment><comment><USER44> We had a similar case in the Netherlands with Starbucks. The European Commission has the argument that if a company has a treaty with a countries tax office that results in them paying less tax than other companies without such a treaty would, then the EC regards that as a state subsidie of a company by that government. A European government is prohibited to subsidise companies in a free market (there are exemption under law), they declare this an illegal subsidie and the government must get the illegal subsidie back. As fare as I am aware, Apple is not being fined in this case, the Irish government is. Its up to the Irish government to continue this subsidy, they just will be fined again if they do. Apple seems to say here that they might withdraw from Ireland because of the uncertainties around their tax evasion strategies, not because they will actually be taxed more.

</comment><comment><USER45> I read two things in this:

\- We bring work and employ a lot of people so we are good.

\- Be careful because if we don't get it our way we are going to go away and you are the one that will suffer.

<comment><USER46> Well, where would they go?

All EU countries will be subject to the same law, and I doubt they would just stop selling their product on the european market (it would still make them money even when paying normal taxes).

Paying customs tariffs would probably be worse than paying taxes in the EU, too.

<comment><USER47> > Well, where would they go?

Any country that would give them large amounts of tax credits. I'm sure some countries would be willing to negotiate.

> I doubt they would just stop selling their product on the european market > (it would still make them money even when paying normal taxes).

They could sell to resellers who would sell in Europe, if it came to that.

<comment><USER48> Adding another layer isn't going to help them, the tax will need to be paid and the additional layer will incur additional costs.

<comment><USER47> But still, people in Europe would be able to get iPhones, even if the cost is higher. They would never be banned like illegal narcotics.

</comment></comment></comment></comment></comment><comment><USER49> [https://en.wikipedia.org/wiki/Double_Irish_arrangement](https://en.wikipedia.org/wiki/Double_Irish_arrangement)

</comment><comment><USER50> Saying that "It (Apple) has helped create and sustain more than 1.5 million jobs across Europe" is a far stretch if the majority of that number are app developers for who it makes no difference where Apple is located.

</comment><comment><USER51> Hmm. I'm not sure whether Ireland owes any money to bondholders. If they do, this EU ruling will make it harder for them to negotiate with those bondholders, who can say "collect your taxes and pay up."

But, some bondholders are probably the same people who compel American companies with vast cash piles to stash them offshore.

Is this an issue for Irish voters? Their government made a deal that cost them money. If it's OK with the voters, their government can fight the EU on this. Or, if the voters prefer, the Irish government can try to collect from Apple.

After all the posturing is done, they'll probably settle quietly.

</comment><comment><USER52> Didn't even know "The Apple Community in Europe" was a thing.

<comment><USER53> Apple writing a rebuttal to the EC decision and addressing it to "the community" seems a lot like Twitter celebrities writing rebuttals addressed to their followers. Anyone else get the feeling this is Apple trying to mobilise its loyal fans against the EC?

<comment><USER54> This ... is pretty much exactly what they're trying to do. It worked reasonably well for them against the FBI, so they're trying it here.

<comment><USER53> If so, that's insane. Why would EU citizens side with Apple against the EC if the only benefit is that Apple has to pay less taxes?

Against the FBI it worked because it actually had direct implications for their customers. But in this case there's no implications for their customers other than a vague threat that Apple will punish them (by punishing the EU market) if they have to pay more taxes -- that's not a rallying call, that's blackmail.

</comment></comment></comment></comment><comment><USER55> Interesting. Does this imply that the UK deal with Google to let them pay less tax is now de jure illegal as well?

<comment><USER56> Most likely that's illegal too. However I'm not sure if they will pursue given the circumstances(UK out in a year or so).

</comment></comment><comment> tuna-piano One side note I haven't seen covered yet:

The court ordered Apple to pay the penalty of 13 billion euros, plus interest. For the last couple years, many bonds in Europe have been sold at negative interest rates. Does that mean Apple could potentially be paying less than 13B back?

</comment><comment><USER57> I can't say I approve of corporate or tax inversion, and I'm not sure what to think of this article. I've read countless articles saying the opposite [http://www.theverge.com/2016/5/5/11604704/apple-tax- evasion-...](http://www.theverge.com/2016/5/5/11604704/apple-tax-evasion- cupertino-mayor-barry-chang-reform)

</comment><comment><USER58> "The European Commission has launched an effort to rewrite Apple's history in Europe, ignore Ireland's tax laws and upend the international tax system in the process."

Wow, strong stuff.

</comment><comment><USER59> The real issue here is that a multinational tax-avoidance scheme is only available to large corporations. This means that their smaller competitors who do not have millions to spend on lawyers each year are taxed at the insane rates of their local jurisdictions. The larger competitors shield their incomes from those same rates, making them more competitive than the smaller companies.

This pay-to-play scheme, coupled with other regulations tailored specifically for large corporations, keeps them shielded from upstart competition. The best thing for consumers and business alike would be to slash the taxes and regulations, instead of going after what the companies "owe" the government -- as if a group of bureaucrats in some capital city have any justified prior claim on the fruits of someone else's labor.

</comment><comment><USER60> Given the current political context in Europe (Brexit, fears of populations across the continent of loosing their sovereignty to Brussels (i.e the EC), the message of Tim Cook is very political and bold: -"We believe these changes should come about through the proper legislative process, in which proposals are discussed among the leaders and citizens of the affected countries" \- "This would strike a devastating blow to the sovereignty of EU member states over their own tax matters" I am not sure this is the way to go. Apple should fight this decision on a legal basis: laws cannot be retroactive - and not a political (borderline populist) one.

</comment><comment><USER61> Is this really that simple? Is the EC actually trying to apply a retroactive law?

<comment><USER62> In a sense: yes. Apple made a deal with Ireland as to their taxation; the EU ruled it illegal, and judged that both parties must act like the agreement was never there.

That means Apple is due taxes to Ireland.

In a sense, Ireland is the guilty party. They entered the EU; that means they agreed with its rules. Later they made an agreement with Apple that is now ruled illegal in the EU. Yet, they will profit (in the short term) if this ruling will stand.

Note that Apple's only published issue is with the retroactive part.

Open question is whether Apple handled in good faith making that deal. I do not rule out judges would rule they did, because there are zillions of such deals, and because the EU doesn't mention anything about fining Apple (they 'just' have to pay the taxes they are due, with interest)

<comment><USER56> I doubt the deal was in good faith. They have an army of lawyers so most likely they knew about this it but took the risk.

<comment><USER62> I don't think that implies not being in good faith. Bad faith would be if they knew the EU would rule this illegal, but still continued with this.

You pay your army of lawyers avoid that. You want to walk extremely close to the edge, but not drop from it.

<comment><USER56> The fact is that it was illegal. It didn't need a rule to decide its legality. I can only speculate that they didn't expect to be forced to pay all the tax back. Perhaps they expected a kind of warning given the local government was on their side. There were/are others doing this (i.e. Microsoft,Google etc) so they decided to stick with the herd.

</comment></comment></comment></comment></comment><comment><USER63> I am sorry Apple, but that message made you look like you are excusing yourself for paying no tax.

</comment><comment><USER64> It bothers me that Apple has probably done the market research and identified that they have such a strong brand among some people that these messages work. First the FBI one and now this. Both misrepresented facts to make Apple look flawless.

The truth is already debatable in the US ('I don't believe the media / government agencies / research from the educated elite'), having corporations jump in to directly muddle the waters doesn't help.

</comment><comment><USER65> Seems like it boils down to determining who gets to make tax law in the EU. Is the EU able to levy taxes on citizens of their member nations directly? Or, are the nations themselves responsible? I'm not sure the legal structure of the EU gives Brussels tax authority. This will be an interesting question to see resolved. It will tell us a lot about the future of the EU.

</comment><comment><USER66> State aid has been forbidden or at least heavily regulated in the EU since the Treaty of Rome in 1957, although Ireland joined later in 1973. No need to play the victim here and stoke anti-EU feelings. Apple got caught, and rightfully so. Time to pay up what is due. Hopefully, others will follow.

</comment><comment><USER67> I see a battle between two sides here in the comments which basically winds down to capitalism vs big government.

There is an incredible amount of corruption in both areas, and even between them (we call this "crony capitalism"). Both within the government, and within the private sector, corruption can be used to squeeze money out of the general population. Both have necessary roles, and their benefits usually outweigh their level of corruption. But to take the side of one or the other is a rather fruitless exercise.

Instead, effort should be focused on how to improve the laws so that we can make them work well for all parties involved, especially the general population. And sadly, its beyond the level of conspiracy at this point that the people who control the laws are the people who benefit most from them.

</comment><comment><USER68> A Message to the Apple Company in the US: sorry, we can see through your shabby PR piece.

Pay.

</comment><comment><USER69> I totally get that Apple should pay more tax. However I also understand that it must not be pleasant to be caught between two hammers.

UE want them to pay more taxes to them because of this wrongful loophole... USA want them to pay more taxes because of this wrongful loophole...

Maybe it's only common sense for Apple to wait that USA and UE define exactly what is actually the lawful taxes process that must replace this no longer existing loophole.

Also the very notion of retroactive "crimes" is usually not compatible with a healthy democracy. How can you be condamned for following instruction a sovereign state (Irland) gave you?

</comment><comment><USER70> Does anyone feel like Apple might start abusing the "open letter" format whenever they're in hot water? Since they're so famous for ubiquitous brand representation, it automatically grabs your attention when a letter written by the CEO himself is posted. Even if it's subconscious, I'm sure some people (me included) read the letter and think that if it's important enough for Tim Cook to write passionately about, on the main site of his company, then Apple's probably in the right.

I wonder how many more open letters we'll be seeing in the next few years.

</comment><comment><USER71> _At the time, the company knew that in order to serve customers in Europe, it would need a base there._

Are you sure this had nothing to do with avoiding US tax and keeping a cash stronghold in Europe?

</comment><comment><USER72> I think the most important question is how often does the US Federal government overturn special deals arranged by State governments for favoured companies?

Europe is in the midst of deciding if it wants to Federalise - and it's unprecedented to do this without war or the expectation of war.

Additionally most countries are in a race to the bottom in collecting MNC taxes.

The two issues are heavily intertwined and this is just the first "battle" that has risen to attention

It's going to be interesting to see what artillery both sides have.

</comment><comment><USER73> Interesting and seemingly overdue.

What effect might this have on Apple (and others) repatriating overseas monies back to the US now. If it's going to be taxed overseas anyway, the argument for holding large amounts outside the US seems to be reduced.

Granted, there will still be other non-US tax havens, and I'm guessing the lower rates may still be a factor. But might this have any impact at all? Or will this just be seen as a small fine and companies will carry on as before?

</comment><comment><USER28> It seems the EU didn't learn their lesson with the UK and Brexit, and they continue meddling in the affairs of sovereign states by interpreting the rules however and whenever they see fit. I wonder what percentage of this tax Brussels expects to appropriate for itself. It's high time to put an end to this failed experiment and especially to the corrupt EC...

<comment> k-mcgrady >> "I wonder what percentage of this tax Brussels expects to appropriate for itself."

The money is going to Ireland. It is not a fine but back payment of taxes owed.

Looking at it from a 'brexit' perspective it's yet another reason I'm disappointed we left the EU. It's powerful enough to do something about this while our own government can only wrangle £130m out of Google.

<comment><USER28> But if this money is collected by Ireland and goes into the Irish budget, wouldn't Brussels get a cut?

<comment> k-mcgrady The EU will get money from it because Ireland owes money due to the bailout a few years ago and membership contributions I suppose. But those are things Ireland would be paying with or without this ruling. At least that's my understanding.

</comment></comment></comment></comment><comment><USER20> Apple got a sweetheart tax deal from Ireland.

Tesla got a sweetheart tax deal from Nevada.

Pfizer got a sweetheart tax deal from the United States.

I don't see the difference.

<comment><USER56> Hopefully this will make a difference(at least in the EU).

</comment></comment><comment><USER74> I love to see Apple get hit with the kind of taxes that they themselves put on the marketplace with their over-priced hardware and the 30% cut that they take from the captive/locked-in audience of developers and users.

Down with Apple. They are a drain on society and they deserve everything they're getting right here.

</comment><comment><USER75> The Joy of tech on this story: [http://cdn.iphonehacks.com/wp- content/uploads/2012/04/joy-of...](http://cdn.iphonehacks.com/wp- content/uploads/2012/04/joy-of-tech.png)

</comment><comment><USER76> This actually the worst piece of public opinion I have ever read from Tim Cook. It hurts their brand, it exemplifies American ego when it comes to dealing with other countries (please, don't tell me that you not paying taxes is some kind of sovereignty crisis for f __* 's sake) and worst of all, it's poorly targeted. It's Europe - on average we do not like big corporations and we laugh on 'liberties', which are in fact money extortion by big players. I do not know who in Apple PR greenlighted this, but he/she might not survive the consequences.

<comment><USER77> Indeed. I was angered by the letter for precisely those reasons as well.

</comment></comment><comment><USER78> > Countless multinational companies followed Apple by investing in Cork, and > today the local economy is stronger than ever.

Is the local economy in Cork much better than the rest of Ireland? I tried to search data that supports the Apple's statement and couldn't find any.

</comment><comment><USER79> Don't blame Apple, blame the tax laws.

i.e. don't hate tha playa, hate da game.

<comment> k-mcgrady No, blame Apple. And the other companies exploiting these laws. Companies can choose to be good citizens and socially responsible. Apple doesn't need to be environmentally friendly - it chooses to. $14.5bn is a drop in the ocean of their $200bn cash stockpile that they can't even use, they can easily pay this. It's not going to hurt their ability to compete even if everyone else is doing it.

<comment><USER80> Billion not Million, although still a small number in respect to 200bn its 7%. But I think you have to look at it in terms of the magnitude of the number, its easy to make it look small in comparison to their reserves but 14 billion is still enough to power a whole lot of economic growth.

<comment> k-mcgrady I edited my comment as I was aware it was billion not million, it was just a typo. I think my point still stands though. If Apple were to pay the correct tax and MS, Google, FB still didn't Apple has so much money that it doesn't effect their ability to compete. In other words they can still win without playing this game.

</comment></comment></comment></comment><comment><USER81> EU should consider this hypothetical:

Imagine that aliens from a remote galaxy came to Earth to trade. They sell alPads and alPhones. They don't have any papers about how those were created and what kind of costs they paid in their galaxy. It was so long ago no one remembers and why would it matter anyway, maybe alPads and alPhones grow on trees in their world.

Now consider how we would like to tax those. Is VAT enough? If not maybe tax for land where they open their office? Whatever you decide do the same with foreign companies in Europe. It's the only way as digging into costs/deals in other countries which may not even be friendly with EU in the future doesn't make much sense.

</comment><comment><USER82> The letter is gross but I don't understand why all this is specifically about Apple? Aren't they using the same kind of tax accounting other multinational companies do?

</comment><comment><USER83> Forgive my ignorance, but what would happen if Apple chooses to ignore this ruling and doesn't pay any retroactive tax at all?

Could it still be business as usual?

</comment><comment><USER84> Thank you my fellow apple fanbois and apple employees for flagging this thread. Has it been on the internal company slack?

</comment><comment><USER85> Could someone please explain why this isn't on the top of the front page anymore?

<comment><USER86> The answer to that question typically is: Because people flagged it, and possibly the many comments going back-and-forth look like a flamewar (which AFAIK also causes a lower scoring).

Also, there are already multiple discussions about the base topic, not sure if another one helps much... (which might be one reason people are flagging)

<comment><USER85> Thank you. I always thought it was somehow only about a correlation between submission time and vote count.

</comment></comment></comment><comment><USER87> Designed by Apple in Ireland

</comment><comment><USER88> Why did this fall off of the startpage?

</comment><comment><USER89> Well, at least they used a bit of those billions to hire a good PR team. I'm always surprised how often press releases are tone deaf.

</comment><comment><USER90> With a bit of luck this will trigger an Irexit.

<comment><USER91> So Ireland will loose access to the EU market and all those double irish deals are worthless?

</comment></comment><comment><USER92> What a load of corporate BS. How does it make first place on HN?

"The European Commission has launched an effort to rewrite Apple's history in Europe, ignore Ireland's tax laws and upend the international tax system in the process."

Please. They got caught not paying any tax in Europe. Ireland's tax laws are not ignored (EU simple asks Ireland to tax Apple according to usual Irish rules) and there is in effect no agreed upon international tax system anymore (if there ever were).

"The opinion issued on August 30th alleges that Ireland gave Apple a special deal on our taxes. This claim has no basis in fact or in law. We never asked for, nor did we receive, any special deals."

This is irrelevant. There was an understanding that Apple could channel all European profits through Ireland and that the Irish government wouldn't tax them on it.

"We now find ourselves in the unusual position of being ordered to retroactively pay additional taxes to a government that says we don't owe them any more than we've already paid."

First of all, it isn't retroactively. The obligation not to receive subsidies was there all the time. Second, it isn't at all unusual. Numerous companies in Europe have had to pay back subsidies, including tax subsidies, to governments that didn't want them back.

"The Commission's move is unprecedented and it has serious, wide-reaching implications."

If by wide-reaching implications they mean that corporations can't hide behind phony company structures and will have to pay tax, then yes.

"It is effectively proposing to replace Irish tax laws with a view of what the Commission thinks the law should have been. This would strike a devastating blow to the sovereignty of EU member states over their own tax matters, and to the principle of certainty of law in Europe."

The EU commission is proposing no such thing. It is merely calling a spade a spade. Ireland joined the EU openly, and signed the EU treaty that bans state aid.

"At its root, the Commission's case is not about how much Apple pays in taxes. It is about which government collects the money."

As in no government, apparently.

"Taxes for multinational companies are complex, yet a fundamental principle is recognized around the world: A company's profits should be taxed in the country where the value is created. Apple, Ireland and the United States all agree on this principle."

Yes, it's complex, and much more complex than a company having to be taxed where the value is created. There is no such agreed upon fundamental principle, not even with United States, and even if there were, I would argue that most of the value is created where the products are either produced or sold, not where the R&D department happened to be located or where a company had placed its IPR.

<comment><USER91> Don't know why you get downvoted, but such a embarrassing, slimy letter from Cook is relevant for HN. I guess he just killed a lot of his credibility with this sniveling letter.

</comment></comment><comment><USER93> After they pay their taxes, I imagine they will post some billboards like this:

Dear EU,

Please use some of the €13 Billion in taxes to keep art in schools.

Love, Apple.

<comment><USER19> Apple is more than welcome to express interest in the education of people they plan to employ, to whom they plan to sell computers.

They begged for clear and fair tax principles for years (up until this letter) and this is happening. It just so happens that if they contradict themselves, or lie, the EU will stop listening.

</comment></comment><comment><USER94> I wonder how much this has to do with the Brexit :)

<comment><USER39> Not much, so far at least. This latest round of trouble over Apple in Ireland predates the Brexit vote. And of course the Republic of Ireland is not in the UK.

</comment></comment><comment><USER95> Funny the total brainwashing that is going on in this statement by Apple.

Look, Apple failed to pay _SALES_ taxes. And now they are trying to mix _SALES_ taxes with the _LABOR_ taxes of those 60 (sixty) people they actually employ in their operation in Ireland.

Apple is the most valuable company in the world, has a huge bank account just sitting there, and yet, they think they shouldn't have to pay taxes.

</comment><comment><USER96> It's time to bring the money back and create jobs in U.S. Apple cannot expect the U.S to cover it's ass from EU. Tim's answer 'well the taxes are high here, so we cannot bring the money back' is not valid because guess what - my taxes are high too and I end up paying them.

<comment><USER97> Apple is de facto a multinational corporation. Heck, it seems it's a supranational corporation even. In that context, what does "bring the money back" mean?

<comment><USER96> Aren't the core of it's operations incorporated in U.S?

</comment></comment></comment><comment><USER98> Am I missing something, last time I looked they barely payed taxes in the US, so the argument is a bit of a moot point.

</comment><comment><USER99> Assuming the main story has tripped some sort of flame war trigger?

[https://news.ycombinator.com/item?id=12388601](https://news.ycombinator.com/item?id=12388601)

223 votes in 3 hours and it's half way down page 2?

It's incredibly important news, shouldn't dang et al intervene and reinstate it?

<comment><USER100> I think the reason for this is that this is the "please don't take the 13 thousand million dollars I owe" response letter from Apple, which probably disgusts a lot of people.

<comment><USER101> It is absolutely relevant.</comment></comment></comment>


Andre Guzman: Time Is Running Out [video] - <AUTHOR> https://www.youtube.com/watch?v=xeh3vOJDXz8 <comment><AUTHOR> Yes, yet another climate change video. But an articulate, calm speaker, short and sweet presentation, and some clear numbers and scenarios to help understand what is at stake.</comment>


Don't hold your breath over 'promising' Federal Reserve report - <AUTHOR> http://nypost.com/2016/08/05/dont-hold-your-breath-over-promising-federal-reserve-report/ <comment><USER2> New York Post isn't "news".</comment>


The Aesthetic Splendor of "The Simpsons" - <AUTHOR> https://www.newyorker.com/culture/rabbit-holes/the-aesthetic-splendor-of-the-simpsons <comment><USER2> On the off-chance any Simpsons fans here haven't seen it yet, Frinkiac [0] is a really fun tool (and generally cool project) that makes every shot of the series searchable by dialogue.

[0] [https://frinkiac.com/](https://frinkiac.com/)

<comment><USER3> A must-have resource for the work-Slack shitposter.

And don't forget [https://morbotron.com/](https://morbotron.com/) \- same thing, but for Futurama.

</comment></comment><comment><USER4> The color palette they tend to stick to always reminds me of EGA graphics (1987) - although the color choices in The Simpsons (1989) are a bit more refined than what's available in the _default_ EGA palette.

EGA allows for redefining the default 16 color palette from a choice of 64 colors. They look quite Simpson-ish to me:

[https://en.wikipedia.org/wiki/Enhanced_Graphics_Adapter#/med...](https://en.wikipedia.org/wiki/Enhanced_Graphics_Adapter#/media/File:EGA64_Full_Palette.png)

Related:

"Why did DOS games never use anything but the default EGA palette?"

[https://www.vogons.org/viewtopic.php?t=31882](https://www.vogons.org/viewtopic.php?t=31882)

</comment><comment><USER5> The author's description of the experience of being able to linger over a particular scene reminds me of why I like video game music so much. When I'm listening to the Breath of the Wild soundtrack, I engage with the game in what I feel is a much deeper way.

Or when I'm watching clips of television shows on YouTube. Attention is compressed and highlights and expands parts of the experience in an almost richer and denser way than the first watch or playthrough.

I wish copyright holders would loosen up some when it comes to derivative works and be freer with licensing deals. Every single engaging story and game world could have an order of magnitude more audience attention if we could let loose the young would-be creators of the world at them.

</comment><comment><USER6> I have recently had a long-time fandom of the show turn into a personal obsession, that's even grown into infecting my friends.

We discuss who wrote the episode, analyze the balance of writing and visual gags, identify voice actors - on and on. I have a strange and personal passion for it.</comment>


'No compelling technical reason to return to Windows,' says Munich's IT chief - <AUTHOR> http://www.techrepublic.com/article/linux-in-munich-no-compelling-technical-reason-to-return-to-windows-says-citys-it-chief/ <comment><USER2> C.R.E.A.M</comment>


A Summer of Julia 2019 - <AUTHOR> https://julialang.org/blog/2019/05/jsoc19 <comment><USER2> Congrats to all the students and good luck to all of them.

But this is personally so disappointing to see no work on PackageCompiler.jl. I think PackageCompiler.jl + some sort of core support for interfaces and traits checked at compile time is what Julia sorely needs. Right now there's just SOOO much boiler plate and resorting to a third party package to solve these problems in the language is starting to get to me. Coupled with the fact that if I want someone to use my code I need to get them to install Julia, configure their environment and run things in a very specific way and I'm looking for another language to put my weight behind.

Anyone else want to share insights about writing large applications and deploying it to users in Julia?

<comment><USER3> We're looking into implementing the language on our platform so folks have the option of deploying it using Docker/K8s.

Would love to get your feedback if you're interested? Also happy to exchange thoughts and insights as well if you have time.

<comment><USER2> I think it'd be great to have a discussion about this. I think the best place might be a thread on Julia's discourse forum. If you want to start a conversation I'll chime in. I'm interested to see what you have going on as well.

<comment><USER3> Thanks. Sounds great - I'll start a thread there then.</comment></comment></comment></comment>


New Radiotracer Can Identify Nearly 30 Types of Cancer - <AUTHOR> https://www.snmmi.org/NewsPublications/NewsDetail.aspx?ItemNumber=31744 <comment><USER2> I was diagnosed with NET cancer recently and my doctor incorrectly ordered the older radiotracer scan. It only showed 1/2 of my tumors, missing the most important primary tumor. This newer scan/radiotracer showed double the number of tumors including the most important step of finding the primary. I will soon have cytoreduction surgery to remove the tumors. Unless you have other biomarkers showing cancer, the issue for this scan is cost - $2-5K. You would not do it casually. Contact me if you want to see a side by side comparison of this new scan beside an older one.

<comment><USER3> Thanks for sharing. You got FDG PET ("older") as well as FAPI? Are you in the US? Curious if FAPI is already in wide use.... does FDG not work that well for NET ?

<comment><USER2> I am in the US and FDG PET does not work for NET. The "older" scan was Pet radiolabeled with indium-111. Comparison is here: [http://prntscr.com/o02jsg](http://prntscr.com/o02jsg) Left is the newer scan, which uses Gallium 68. The primary tumor is uppermost right side, liver metastasis is left side, and small lower lighted up areas are lymph nodes. All will be removed soon. Lit up area below is the radiotracer in my bladder before urinating. :-)

<comment><USER4> Wow! Do you have DICOM files for that! Good thing they found all that! Good luck with all the surgery, you'll get better soon!

<comment><USER2> Yes I have all the Dicom files and put all the images on a password protected server so I can share with prospective surgeons. This really helped me find the best possible surgeon. THANKS!

<comment><USER5> Minor side note: I did that too but found that institutions were locked down and could not access my public server, and they wouldn't accept a usb drive with the same data. They were only set up to receive FAT dvds - and I spent many, many hours duping DVD's for doctors in their waiting rooms.

<comment><USER4> The USB thing might be a security policy in action. The DVD (and that's weird, because I think I've never seen DVDs, but lots of CDRs) is probably a historical thing related to the DICOM Supplement 19 General Purpose CD-R Image Interchange Profile standard.

</comment></comment></comment></comment></comment></comment></comment><comment><USER6> Anyone have any experience getting tested for cancer when marked as "healthy"? I contacted my PCP and some other random places asking to get a cancer screening and nobody would give me the time of day - "that's not done".

At most they said they would do a blood test which checks for a couple types of cancer. I asked if I could get a CT and have a professional go over it. nope. But something like this tracer is what I'd like to do.

<comment><USER7> MD here. It's "not done" because it could hurt you.

Here's the Bayesian argument:

\- Let's assume a lab test (or imaging test) has a 1% false positive rate and 100% sensitivity (that would be pretty good for many tests and imaging modalities!).

\- The cancer you screening for has a 1% incidence as well (low-ish, for the sake of argument).

\- Therefore the chance that a "positive" scan would be due to a false positive or a true cancer would be equivalent (i.e., the Positive Predictive Value is 50%).

If we did this at population level, we'd be massively overtreating and over- biopsy-ing... not the desired outcome.

<comment><USER8> Maybe figure out a better way to verify that doesn't require biopsy? Maybe use machine learning in conjunction with better data? I don't know enough but there must be other techniques we could devise that don't require major invasive surgery every single time.

Just sitting on our hands on this information and letting people die is the worst decision. We need to improve our technology to get better results, not throw our hands up in the air and say the problem is too hard.

<comment><USER9> Well the ways that don't involve surgery are themselves less accurate heuristics with false positives. How can they calibrate without being certain if it is a true or false positive or negative?

Better imaging is an option but that often falls into dangerous in itself or easier said than done like say trying to do detection of cancer by scent.

Machine learning is fundamentally GIGO and tends to learn smartass shortcuts if one isn't careful. "The healthy sample data is less zoomed in while the cancer ones are zoomed in - therefore full chest x-ray is fine but a lung X-ray is cancer."

<comment><USER10> My limited experience is that for small contained cancers imaging can't predict the future course for the tumor because you need cellar resolution that you can't get without a biopsy and a microscope and or genetic tests.

Even then it's really common to see a biopsy come back as 'indeterminate'. If it's indeterminate then now what? You either punt and do nothing or go for excision.

Consider this tidbit: A lot of slow moving low grade cancers it hardly matters when you find them. Early or later matters little. Whereas aggressive cancers often are untreatable. Find them early, find them late you'll die either way. And fast growing cancers often fully develop between screenings.

<comment><USER11> In other words - you're dead either way - go have a beer instead?

</comment></comment></comment></comment></comment></comment><comment><USER12> Have been chatting with a radiation oncologist about this. His response: "imaging appears to be the same as F18-FDG-based PET. Just a bit more convenient since the patient doesn't need a normal blood sugar. And prob 2-10x the price"

<comment><USER13> The great advantage of these tracers is that they target actual structures over-expressed in cancers, which means they show far higher specificity than something like FDG. That means they can be used to find micrometastases, and with a different radio-label also be applied for highly targeted radiation therapy.

Source: I used to work in the Heidelberg lab that published this study.

</comment></comment><comment><USER14> That CT image of the breast cancer patient... Ouch. Not easy to look at.

<comment><USER15> This happened to my mom when she had breast cancer. I wonder if this is a normal progression with that type of cancer? I have no idea why they did it, but they did do an autopsy when she died and her doctor basically said she was riddled with tumours throughout her entire body (she lived 7 years with cancer after diagnosis, who knows how long before). When I saw these images that's immediately what I thought of. It's very unsettling.

</comment></comment><comment><USER16> Really impressive images with apparently regular PET-scans, so could be available for general use rather quickly. It's advances like this that enable medicine.

</comment><comment><USER17> Classic example of marketing to the naive ....</comment>


Why Android will not catch the iPhone - <AUTHOR> http://www.hasemanonmobile.com/2009/08/20/androids-attitude-problem/

<comment><USER2> What gives me hope for Android is all the people coming out of the woodwork insisting it's going to fail. There has to be something to Android to keep it in our collective consciousness, right?

I mean, we're not talking about how Symbian or WinMo devices will never catch the iPhone.

It doesn't have to be number 1 to be worthwhile; if the Android platform had even a quarter of the ecosystem the iPhone has, it would be an enormous success.</comment>


AMD announces CUDA support - <AUTHOR> http://www.anandtech.com/show/9792/amd-sc15-boltzmann-initiative-announced-c-and-cuda-compilers-for-amd-gpus <comment><USER2> No, it didn't. The title is misleading, AMD is announcing tools to make it easier to port from CUDA. Not the same as supporting CUDA, which is owned by nVidia only. Unless nVidia open-sources CUDA, AMD cannot do anything for it.

The article said the same thing:

> Through HIP AMD will bridge the gap between HCC and CUDA by giving > developers a CUDA-like syntax – the various HIP API commands – allowing > developers to program for AMD GPUs in a CUDA-like fashion. Meanwhile HIP > will also including a toolset (the HIPify Tools) that further simplifies > porting by automatically converting CUDA code to HIP code. And finally, once > code is HIP – be it natively written that way or converted – it can then be > compiled to either NVIDIA or AMD GPUs through NVCC (using a HIP header file > to add HIP support) or HCC respectively.

> To be clear here, HIP is not a means for AMD GPUs to run compiled CUDA > programs. CUDA is and remains an NVIDIA technology. But HIP is the means for > source-to-source translation, so that developers will have a far easier time > targeting AMD GPUs.

What's even worse is that it may not be legal either:

> Now there are some unknowns here, including whether AMD can keep HIP up to > date with CUDA feature additions, but more importantly there's a question of > just what NVIDIA's reaction will be. CUDA is NVIDIA's, through and through, > and it does make one wonder whether NVIDIA would try to sue AMD for > implementing the CUDA API without NVIDIA's permission, particularly in light > of the latest developments in the Oracle vs. Google case on the Java API. > AMD for their part has had their legal team look at the issue extensively > and doesn't believe they're at risk – pointing in part to Google's own > efforts to bring CUDA support to LLVM with GPUCC – though I suspect AMD's > efforts are a bit more inflammatory given the direct competition. Ultimately > it's a matter that will be handled by AMD and NVIDIA only if it comes to it, > but it's something that does need to be pointed out.

Why the heck would any developers use HIP with this legal issue up in the air?

<comment><USER3> > Why the heck would any developers use HIP with this legal issue up in the > air?

Probably because if just implementing an API really turns out to be a disallowed by law - and I'm not familiar enough with the Google/Oracle case in particular or the law in general to know how well it generalizes to such a conclusion - then most of the stuff I rely on goes poof anyway.

<comment><USER4> The way the Oracle/Google case got resolved was that the Federal Circuit made a ruling that almost everyone agreed was wrong with respect to the copyright issues but that there was little danger of any other circuit ruling that way on future cases that didn't have a patent aspect to get them in front of the Federal Circuit. Part of the Supreme Court's reasoning for not taking up the issue probably was that the Federal Circuit hadn't and couldn't create any binding precedent in the matter (as they were supposed to be following the local circuit's law on the non-patent aspects of the case).</comment></comment></comment>


Target Employees Won the 'Fight for $15' but Weren't Ready for the Trade-Offs - <AUTHOR> https://reason.com/2019/10/21/target-15-bucks-per-hour-didnt-work-out/ <comment><USER2> Alternatively, Target decided to hike wages _because_ they were already planning to cut insurance benefit outlays, softening the blow.

<comment><AUTHOR> An interesting theory, but there's no proof of it, is there?

<comment><USER2> No, there isn't. It's as much conjecture as the thesis of the article.

You can't say the extent to which or even whether a $15 minimum wage would depress hours or benefits without an analysis of the elasticities of the supply & demand curves at Target. The article makes it sounds like such changes[1] are the inevitable consequence of any hike in wages, which is both not only strictly wrong as a matter of Econ 101 (elasticities matter) but also a notoriously contentious area of debate with substantially[2] _conflicting_ _empirical_ _data_.

[1] Presuming the characterizations are correct; they're based on 23 anecdotal employee interviews.

[2] That is, there's _good_ , _solid_ , empirical data (not just numbers- pulled-out-of-butt partisan retorts) for both sides. Which isn't all too surprising because, again, elasticities matter and are by their nature context dependent.</comment></comment></comment>


A hackathon to change the world - <AUTHOR> https://ash.silvrback.com/a-hackathon-to-change-the-world

<comment><USER2> Sounds like a meaningful concept to me.

Based on the same hypothesis, I've been brainstorming on first how to gather people around meaningful discussions & ideas, and then on how to motivate them to implement them. What I came up with is that people need to commit. And to make them commit, they need to be feel motivated, engaged and confident about their goal and their team. And to achieve that, we need recurring events in a trusted place whith trusted people where a strong culture reigns.

One way to implement this is to use existing structures, such as coworking spaces, and provide to their members the possibility to gather in the same place, after work.

Rather than expediting the event like a "startup weekend", I'd rather define a longer-term strategy separated in phases. That kind of program could start with one or two months of weekly discussions, inviting speakers, in order to set minds on the right track. Then the second phase could be focused on the definition of teams and projects. Afterwards, the third phase consists of the implementation of the ideas. People could work on them whenever they want, but a weekly event will still be held to keep track of progress and, more importantly, to exchange feedback. Finally, the last phase would consist on some sort of demo day.

What do you guys think about that?

<comment><AUTHOR> I completely agree, I think there are many ways you could do things on a longer term basis. I think the idea of the "startup weekend" style event has a couple of benefits in this context.

1\. It's a good way to try it and see what happens and learn so you can learn what to improve in the format.

2\. It helps gain momentum because you're only requesting a small amount of initial time investment from people.

3\. One of the key points I wanted to stress was the ability to have organisations on hand to help fill in knowledge gaps about the realties of the situation data etc, and also be able be actively involved in the process. I think it's easier to get them involved in that capacity for one weekend. Then build on there involvement after they see the value etc.

</comment></comment><comment><USER3> I've want to create a nontechnical hackathon at my university around the idea of making the university better for a few months now and the biggest issue I've got is fighting the connotations of the word hackathon.

Startup Weekend is great because they've established this brand around what is essentially a hackathon and doesn't necessarily scare away nontechy people.

I'd be interested to see what the hackathon to change the world ends up attracting in terms of talent type and background and what the final name for the event is.

<comment><AUTHOR> The naming is certainly something I have issues with. I haven't really spent any time thinking about how else to express it but I don't think I will be short of ideas when I do.

In terms of what kind of talent it will attract I have no idea. For me personally I think with the type of issues we want to deal with, diversity is key. You need talent as much as you just need a different point of view.

It's great that you have been thinking about doing something at your university. What other things have you experienced so far ?</comment></comment>


FCC Announces "100 Squared" Iniative:100mbps to 100 million homes - <AUTHOR> http://arstechnica.com/tech-policy/news/2010/02/fcc-wants-260-million-people-on-100mbps-broadband-by-2020.ars

<comment><USER2> Verizon has been promising this for quite a while now. From what I've heard, the third and highest tier of FiOS can only get up to 50mbps (if you're lucky). <http://www.newnetworks.com/tellthetruthverizon.htm>

"We estimate that nationwide, through tax cuts and overcharging, customers have paid an estimated $70 billion dollars for non-existent broadband services. In Pennsylvania alone, we estimate that Verizon already collected $785 per household for services customers never received."

</comment><comment><USER3> As long as the US leads in suburbia, we will follow in last mile bandwidth.

</comment><comment><USER4> Wonder if this will disincent private sector innovation and investment.

</comment><comment><USER5> 10 years is a long time to implement this with only 100Mbps. By 2020 many other countries will be on gigabit connections. I think they're aiming too low here.

<comment><USER6> What are these "other countries"? Yes, one can point to some countries that are doing considerably better on broadband on speed to some customers - specifically Japan, South Korea, and France. After those three, speeds drop off a cliff (to the 10-20Mbps range).

And Not everything is perfect in those countries. About 35% of Japan's broadband users are on lowly DSL. And Japan, while having one of the most urban and tech-savvy populations out there, has _lower_ broadband penetration than the United States. That's right, a greater percentage of Americans have broadband than Japanese people. France, despite its urban population, barely beats the US on broadband penetration and most of it is DSL! A tiny fraction of it (a few percentage) is cable of fiber.

Part of the problem is how the OECD reports on broadband. They report on advertised offers of service (and what speeds companies are advertising as their theoretical maximum). US companies tend to create a uniform structure where they serve their urban areas in the same way they serve their suburban areas.

And it should be noted that the US is 7th in fiber connections and 15th of 30 in penetration all with one of the most subruban/rural populations. So, saying that we're behind is factually wrong. Saying that we're mediocre could be correct.

The US should improve. It needs to improve. However, the situation isn't as dire as many like to make it seem. Many countries are getting in the 10-20Mbps range and the US is on the low end of that at 9-10Mbps. It should improve. It should be a priority. However, it also needs to be noted that the situation isn't as rosy in other countries as people make it out to be and the US does have a more difficult challenge due to its suburban/rural population.

*All statistics come from the OECD broadband statistics.

<comment><USER7> Many countries simply don't have the kind of cable infrastructure that North America has. That makes DSL the only sane choice for existing construction. I would not call ADSL2+ inferior to cable though.</comment></comment></comment>


Ask HN: Is the skills cap in tech as wide as we think? - <AUTHOR>

Just had a support call escalated to me where the resolution involved unplugging a network cable, and plugging it back in.  For about two seconds I was annoyed with the help desk operator who sent me the ticket for overlooking the first troubleshooting step, then the end user having the problem told me these words:
"I'm not smart enough to do that".
Which, had this been something involving poking around with network settings or pinging a server and looking for certain responses...I'd give a pass on.
This was literally reaching over to a desk phone, unplugging the only cable connected (because PoE is awesome like that), and then performing the steps in reverse.
Got me thinking...is there really a gap in tech skills, or has our tech gotten us to the point where we are unwilling or incapable of rudimentary problem solving tasks?
You're a savvy bunch, what are your thoughts here?  How can we resolve this gap or deficiency in critical skills in the workplace? <comment><USER2> Most people are _terrified_ of computers.

And most computer professionals are totally oblivious to this, which is one of the key reasons that so much user-space software (and hardware) really sucks.

Instead of whinging about how stupid people are and heading down the path that leads uphill both ways (and we LIKED it!), put yourself in the user's shoes. Computers are magic to them. When you ask them to do something that _seems_ simple to you, like unplug and replug a network cable, keep in mind that they don't know what a network cable is, or what it does, or what might happen, or why they're being told to do that. They're genuinely scared, and rightfully so, given the horrid experiences most people have had with technology today.

Try accompanying the request for action with an explanation of what you expect it to do (in small words), heavily loaded with reassurance that it will _not_ catch fire and explode or sell their children on EBay or whatever horror stories might be rolling through their minds. Help them feel that the person at the other end of the line, the expert they called (overcoming other fears to even ask for help) is sympathetic, wants them to succeed, and believes in them.

And finally, remember, the wise words of one of the smartest people I know... "Intelligence is like four wheel drive. It doesn't keep you from getting stuck, it just lets you get stuck in worse places."

<comment><USER3> Beat has hit the nail on the head. My day job is consumer sales for a big Australian telecom. Many of my customers visit to buy their first smartphone (!). I'll train them in how to call, text and browse before they leave and drill it in with practice (my sales manager hates the time this takes).

But they're too afraid of breaking the phones to play; too afraid to learn. Apple's 'Do Not Disturb' feature is a common issue - they'll accidentally turn it on, and they can see the half-moon. They remember they need to turn the feature off to receive calls... and 75% of the time they even remember how. But they leave it until they're in-store next - because they are too afraid of causing damage.

</comment></comment><comment><USER4> There's a story often told to entrepreneurs about how elephants are trained to stay on a rope.

Elephants are powerful creatures - they could snap a rope in a heartbeat. Yet, trained elephants can be tied to a post or led around with even a terribly thin rope. So why don't they break free?

It's simple: from birth, they're tied with chains (which they can't break at that age). It is ingrained into their brain that "tied up" == "can't escape". Thus, when they are tied up with mere rope, they assume it will behave just like the chain, and they'll be stuck - so they don't even try.

People often behave the same way with computers. Several bad experiences with trying to fix something themselves, and making the situation worse, imprints them with the belief that they will never be able to fix their computers, and it's much better to simply let someone "who knows what they're doing" (as if we always do) handle it. Add to that the fact that if they try to fix it themselves, they may not remember everything that they tried and could possibly have caused a problem that would render solving the original problem much more difficult, and the fear (real, honest-to-God _fear_ ) much more understandable.

To stand further atop the shoulders of giants in this comment, I'll bring in a well-known (in this neck of the Internet) quote from Arthur C. Clarke: "Any sufficiently advanced technology is indistinguishable from magic". When they have to decide if they can fix it themselves, they are basically asking: "Am I a magician? No -> Okay, I'll take it to someone who is."

One thing I like to keep in mind in situations like this (to stay humble and avoid coming off as condescending) is that if I had a hardware failure, I'd take it to the Apple store right away. No f'n way would I fix that myself - why? _Because I 'd probably make it worse._

</comment><comment><USER5> People don't like venturing into territory where they aren't 100% confident in what they are doing. Especially when it comes to tasks that haven't been programmed into muscle memory.

Solution? Shut down all internet search engines for a year. When people aren't spoon-fed answers to every question maybe they'll start using critical thought as their default mode of operation.

</comment><comment><USER6> As a technology becomes more and more ubiquitous it comes in contact with a more diverse range of people. People take it so much for granted that a person who doesn't know how to connect and disconnect modular adapted cables - something that my grandmother did when replacing the knotted cord on the handset - is the person who is fucking assigned to troubleshoot a network outage!

As little as ten years ago, the person troubleshooting it would either be a trained technician or the office computer guru...then again, I've worked in offices where the equivalent of plugging and unplugging a cable counted as being the in-house expert. And it didn't stop the company from making money.

</comment><comment><USER7> I don't think that the problem is that they are "not smart enough to do that". I think that the problem is that they have given up on ever being able to understand. That's a much harder problem to solve.</comment>


Exploring the GitHub Archive - <AUTHOR> https://blog.wallaroolabs.com/2018/05/exploring-the-github-archive/ <comment><AUTHOR> Hey HN. I'm the author of this post. This post is a starting point for helping people experiment with Wallaroo. I'd be happy to answer questions or discuss some of the ideas that went into this specific project.</comment>


You are Probably under KRACK - <AUTHOR> A new online threat is making waves around the world. Key Reinstallation Attack (aka KRACK) is a network vulnerability that has recently been discovered by Mathy Vanhoef of the imec-DistriNet research group. What's the big deal about this one? It turns out to threaten every modern protected WiFi network and all devices connected to one.
Technicalities
KRACK abuses a massive weakness in WPA2, a protocol used to protect all modern secured WiFi networks. If you are using a protected WiFi network, you can be affected. An attacker can intercept, read, and in some cases manipulate the data transferred via the network. This includes CC numbers and passwords, emails, chat messages, photos – basically anything.
The discovered vulnerability stems from a 4-way handshake confirmation process of the WPA2, executed when you try to join a WiFi network. During this process, parties check if the entered password is correct, and exchange encryption keys. The latter will then be used to encrypt the traffic between a device and a wireless network.
The third handshake normally transfers the encryption key and confirms its receipt. If the reception is not acknowledged, the internet access point will resend the key. Malefactors can intercept these messages and transform them, resulting in your protected WiFi connection using a compromised key.
Due to specifics of Linux and Android, they are especially prone to KRACK. According to Mr. Vanhoef, "currently 41% of Android devices are vulnerable to this exceptionally devastating variant of our attack."
Warding off KRACK dealers
First and foremost, this is a patchable problem, so make sure that your software is updated. Though releasing updates takes time so no way to know how long you will have to wait for it.
Mathy Vanhoef mentioned HTTPS may provide an additional layer of protection against such attacks too. Finally, use a VPN services, like VPN Unlimited, as an additional level of security. <comment><USER2> No patches available for most devices, and unlikely to come.

HTTPS-only traffic is unaffected - you could run that on top of an open wifi, and the worst that could happen would be inaccessible sites due to bad certs. VPN doesn't help if you're interested in local network services.

In all, treat any wifi network as untrusted, and the issue is moot.

</comment><comment><USER3> Implying it's a security issue.</comment>


Playing devil's advocate about Electron - <AUTHOR> http://www.upbeat.it/2017/04/19/playing-devils-advocate-about-electron/ <comment><USER2> "Sometimes you have to compromise, use a technology that requires a bit more RAM and CPU cycles but that allows you to build apps in a quicker way on different platforms. "

I think the issue is that if you're developing an app with Electron, you're asking your _user_ to make a compromise so that _your_ life is easier.

<comment><USER3> I would agree with that quote if it was referring to Java or a scripting language. But developing an application using an embedded web browser as the framework has to be the most inefficient use of resources as possible.</comment></comment>


Still All on One Server: Perforce at Scale (2011) [pdf] - <AUTHOR> http://info.perforce.com/rs/perforce/images/GoogleWhitePaper-StillAllonOneServer-PerforceatScale.pdf <comment><USER2> Google no longer uses Perforce.

[https://cacm.acm.org/magazines/2016/7/204032-why-google- stor...](https://cacm.acm.org/magazines/2016/7/204032-why-google-stores- billions-of-lines-of-code-in-a-single-repository/fulltext)

<comment><USER3> This is correct, but perforce got them to the level they could create their own tooling around git to make it work.

<comment><USER4> Git? I thought Google uses a custom system?

<comment><USER5> We do. It's called Piper: [https://cacm.acm.org/magazines/2016/7/204032-why- google-stor...](https://cacm.acm.org/magazines/2016/7/204032-why-google- stores-billions-of-lines-of-code-in-a-single-repository/fulltext)

</comment></comment></comment></comment><comment><USER6> FWIW, the metadata file locking was improved with lockless reads as of the 2013.3 release, which made a huge difference to ease of scalability.

Various customers with repos in the PB range these days (metadata TB).

Disclaimer: current Perforce employee

<comment><USER7> _Disclaimer: current Perforce employee_

That's a claimer, rather than a disclaimer!

</comment></comment><comment><USER8> Ha! Remember when source control used locks! Waiting 30-60secs for p4 commands...

"we went from seeing the server blocked routinely for up to ten minutes at a time in 2005 to gaps of thirty seconds to a minute in 2010..."

<comment><USER9> Now instead, I run git pull; git push in a loop and hope I can get in before a coworker. Progress?

<comment><USER10> Do you really have that many coworkers that people are pushing _every few seconds on the same branch_?

<comment><USER9> Yes, during the work day, many people would like to commit their changes, often during the same timeframe. Every step takes a second or two, so there's plenty of room to get conflicts (I moved closer to the git server, so now I have an advantage!)

CVS was nice(ish) since changes were independent, any number of people could check in code to limit of io parallelism. Svn was nice, the server would wait for a lock and if my changes didn't conflict, they would be applied after the rest of the pending commits. Git is a PITA, large companies build elaborate systems to queue commits, but we're not big enough to use that yet.

<comment><USER11> Does everyone in your company push to master all the time? Or is it different PRs being merged all the time?

<comment><USER9> Pretty much yes. We like to push to master, and then push to production. Some teams cherry pick changes to a deployment branch and deploy from there instead of master.

Edit to add: We may be "doing it wrong", but this is the least effort way to do centralized development.

<comment><USER8> No seriously, consider git branches. It's gotten 100x easier to create, manage, and merge branch pull requests. Most projects I join these days in fact "lock" master and you are forced to develop in branches.</comment></comment></comment></comment></comment></comment></comment>


Ask HN: Starting a company for new app - <AUTHOR>

What is the best thing to do before you release an app as an individual developer? Should I incorporate or is it best to release it as an individual and then transfer rights afterwards? <comment><USER2> Launch it, get some traction first, then incorporate. There is no law against releasing an app personally and this will save you money if the company doesn't work.

<comment><AUTHOR> But the cost of incorporating is really tiny isn't it (£15 in the UK where I live)? And I'm thinking about what users think seeing an app created by a person vs a company

<comment><USER3> The cost of incorporating in the UK is cheap but you're creating a legal entity so there's more to it than just coming up with a name and parting with the cash. I'd have a read of the following to get an idea of what it entails and what other options you have:

[https://www.gov.uk/business-legal- structures/overview](https://www.gov.uk/business-legal-structures/overview)</comment></comment></comment>