http://online.wsj.com/articles/burger-king-in-talks-to-buy-tim-hortons-1408924294
QuoteBurger King in Talks to Buy Tim Hortons in Canada Tax Deal
Tie-Up Would Be Structured as Tax Inversion With a Combined Market Value of About $18 Billion
Burger King Worldwide Inc. BKW +1.01% is in talks to buy Canadian coffee-and-doughnut chain Tim Hortons Inc., THI.T +2.79% a deal that would be structured as a so-called tax inversion and move the hamburger seller's base to Canada.
The two sides are working on a deal that would create a new company, they said in a statement, confirming a report on the talks by The Wall Street Journal. The takeover would create the third-largest quick-service restaurant provider in the world, they said.
Inversion deals have been on the rise lately, and are facing stiff opposition in Washington given that they threaten to deplete U.S. government coffers. A move by Burger King to seal one is sure to intensify criticism of them, since it is such a well-known and distinctly American brand.
A person familiar with the matter said a deal between the two companies could be struck soon, though additional details on timing couldn't be learned. Tim Hortons has a market value of about $8.4 billion, while Burger King's is about $9.6 billion, so together the restaurant companies are currently worth about $18 billion.
By moving to a lower-tax jurisdiction, inversion deals enable companies to save money on foreign earnings and cash stowed abroad, and in some cases lower their overall corporate rate. Even though many of the headline-grabbing inversion deals of late have involved European companies, Canada has also been the focal point for a number of them, given its proximity and similarity to the U.S. Canada's federal corporate tax rate was lowered to 15% in 2012.
Valeant Pharmaceuticals International Inc., VRX.T +3.06% which had been based in California, combined with Canada's Biovail Corp. in 2010 and redomiciled in Canada. The company now has a tax rate less than 5%
After a tide of tax-inversion deals—including AbbVie Inc. ABBV +0.44% 's agreed purchase of Ireland's Shire SHPG +0.04% PLC and Medtronic Inc. MDT -0.80% 's agreement to buy Ireland's Covidien COV -0.85% PLC, with other deals expected in the coming months—the White House called on Congress to take steps to prevent companies from pursuing inversions. The Treasury Department recently said it is assembling a list of options to deter or prevent the deals for Secretary Jacob Lew to consider.
Nevertheless, Burger King, whose initial approach to Tim Hortons came more than a month ago, doesn't plan to have a provision in a merger agreement that would allow it to walk away from a deal if laws are passed that diminish the benefits of inverting, people familiar with the matter said.
In the current wave of such deals, most inversions have been struck by health-care companies. An inversion deal by Burger King would suggest that the deals have wider appeal beyond the health industry, as companies from a range of industries consider ways to become more competitive from a tax perspective.
Burger King was founded in 1954 with a single restaurant in Miami, where it is now based. It has since grown to be the world's second-largest hamburger chain, according to the company's website. There are more than 13,000 Burger King locations in nearly 100 countries, serving more than 11 million people daily, the site says.
Tim Hortons, based in Oakville, Ontario, is well-known for its coffee, a high-margin business line in which U.S. fast-food giants have raced to grab market share. Burger King has been adding more coffee items and flavors to its menus to catch up with rival McDonald's Corp. MCD -0.08% , which has had success with a specialty coffee line called McCafe. Burger King paired up with Seattle's Best Coffee, a brand owned by Starbuck's Corp., to help its effort gain traction.
In 1995, Wendy's Co. WEN +1.04% acquired Tim Hortons. At the time, the fast-food company's executives were looking for growth outside of the burger market.
Activist hedge fund Pershing Square Capital Management, run by William Ackman, and Trian Fund Management later accumulated stakes in Wendy's and demanded that the company spin off the Canadian chain, which it did in 2006.
Last year, hedge funds Scout Capital Management LLC and Highfields Capital Management LP announced stakes in Tim Hortons and called for the company to curtail its U.S. expansion plans and increase its leverage to buy back more shares.
In 2010, Brazilian private-equity firm 3G Capital Management bought Burger King and took the chain known for its Whopper burgers private. A few years later, the company structured a complex deal with an investment vehicle co-owned by Mr. Ackman to go public again, while retaining control of the company.
3G, which has offices in Rio de Janeiro and New York, has become a major player in the U.S. food sector, with a taste for iconic brands. Billionaire co-founder Jorge Paulo Lemann was a big shareholder in brewer InBev and helped engineer its 2008 acquisition of Anheuser-Busch. 3G last year teamed up with Warren Buffett to buy U.S. ketchup maker H.J. Heinz Co. for $23 billion, one of the largest deals of the year.
A key rationale for the deal is the potential to leverage Burger King's expertise in global development to boost Tim Hortons' international growth, the companies said, adding they plan operate the two as stand-alone brands.
Burger King: Tainted by Tim?
Quote from: Syt on August 25, 2014, 03:56:10 AM
In 1995, Wendy's Co. WEN +1.04% acquired Tim Hortons.
:o Tim Horton's is American!
Quote from: Martinus on August 25, 2014, 03:58:16 AM
Burger King: Tainted by Tim?
Now that would be awesome. :)
Quote from: Admiral Yi on August 25, 2014, 04:00:07 AM
Quote from: Syt on August 25, 2014, 03:56:10 AM
In 1995, Wendy's Co. WEN +1.04% acquired Tim Hortons.
:o Tim Horton's is American!
And yet he lives overseas, ostensibly to avoid corporate taxes.
Quote from: Admiral Yi on August 25, 2014, 04:00:07 AM
Quote from: Syt on August 25, 2014, 03:56:10 AM
In 1995, Wendy's Co. WEN +1.04% acquired Tim Hortons.
:o Tim Horton's is American!
I thought the Feds would step in and prevent such merger, but since they're already Americans, so be it. English Canada's national pride with suffer a little more ;)
Just wait until we come for Canadian Tire.
Quote from: viper37 on August 25, 2014, 01:54:40 PM
Quote from: Admiral Yi on August 25, 2014, 04:00:07 AM
Quote from: Syt on August 25, 2014, 03:56:10 AM
In 1995, Wendy's Co. WEN +1.04% acquired Tim Hortons.
:o Tim Horton's is American!
I thought the Feds would step in and prevent such merger, but since they're already Americans, so be it. English Canada's national pride with suffer a little more ;)
They're Canadian right now...they repatriated several years ago.
Molson (beer) is american. There were some popular "I am canadian" commercials a while back, but that stopped when they got bought out :lol:
Quote from: viper37 on August 25, 2014, 01:54:40 PM
Quote from: Admiral Yi on August 25, 2014, 04:00:07 AM
Quote from: Syt on August 25, 2014, 03:56:10 AM
In 1995, Wendy's Co. WEN +1.04% acquired Tim Hortons.
:o Tim Horton's is American!
I thought the Feds would step in and prevent such merger, but since they're already Americans, so be it. English Canada's national pride with suffer a little more ;)
Wouldn't the "inversion" effectively make the buyer "Canadian"? :hmm:
Edit: in any event, Burger King is owned by a Brazillian firm. Brazil is expanding its empire! :(
That is what they're talking about...making Burger King Canadian to dodge U.S. taxes.
Quote from: Tonitrus on August 25, 2014, 02:34:26 PM
That is what they're talking about...making Burger King Canadian to dodge U.S. taxes.
That's what I thought. But I don't really knoiw how these "inversions" work.
Take that, Viper! English Canada's pride is to receive a boost! :lol:
Well, if you'd call that a "boost". :P
(https://languish.org/forums/proxy.php?request=http%3A%2F%2Fmedia.twirlit.com%2Fwp-content%2Fuploads%2F2012%2F09%2Fburger-king-where-is-your-god.jpg&hash=debec2ab71fdacf9f022909de169230618614dbc)
Quote from: Tonitrus on August 25, 2014, 02:39:03 PM
Well, if you'd call that a "boost". :P
(https://languish.org/forums/proxy.php?request=http%3A%2F%2Fmedia.twirlit.com%2Fwp-content%2Fuploads%2F2012%2F09%2Fburger-king-where-is-your-god.jpg&hash=debec2ab71fdacf9f022909de169230618614dbc)
"Where are your tax dollars now?" ;)
One thing about Tim Hortons - it was named after the famous hockey player who founded it, and who then died in a horrific car crash.
Given that origin, I always thought it in poor taste that they call their signature snack - "Timbits". :D
Quote from: Malthus on August 25, 2014, 02:43:54 PM
One thing about Tim Hortons - it was named after the famous hockey player who founded it, and who then died in a horrific car crash.
So, in a way, you could say he was a king in the rink, and burger on the highway. As it were.
Time to boycott BK.
For most military bases, the singular fast food restaurant on base is a BK. :(
Quote from: Tonitrus on August 25, 2014, 03:02:47 PM
For most military bases, the singular fast food restaurant on base is a BK. :(
All your base are belong to us.
:D
Quote from: HVC on August 25, 2014, 02:18:53 PM
Molson (beer) is american. There were some popular "I am canadian" commercials a while back, but that stopped when they got bought out :lol:
Who bought them? Bud and Miller are foreign owned now, so I'm surprised there's anyone with left to buy them.
Quote from: Admiral Yi on August 25, 2014, 03:21:24 PM
Quote from: HVC on August 25, 2014, 02:18:53 PM
Molson (beer) is american. There were some popular "I am canadian" commercials a while back, but that stopped when they got bought out :lol:
Who bought them? Bud and Miller are foreign owned now, so I'm surprised there's anyone with left to buy them.
They "merged" with Coors to form Molson Coors.
Asoka.
Corporate taxes are lower in Canada.
I wouldn't have corporate taxes at all. It is double taxing.
Can you imagine the boost to the economy if we were to drop that tax?
Quote from: Siege on August 25, 2014, 07:51:36 PM
Corporate taxes are lower in Canada.
I wouldn't have corporate taxes at all. It is double taxing.
Can you imagine the boost to the economy if we were to drop that tax?
As long as every corporation that claims to be a person files a 1040.
Quote from: Siege on August 25, 2014, 07:51:36 PM
I wouldn't have corporate taxes at all. It is double taxing.
Not really. Tax rates are adjusted, for dividends, mainly. That way, in theory, for a Canadian business and a Canadian shareholders, the total tax rate (corporate+personal) is similar to having all revenues to the individual.
That's in theory, of course.
Quote from: viper37 on August 25, 2014, 10:45:54 PM
Not really. Tax rates are adjusted, for dividends, mainly. That way, in theory, for a Canadian business and a Canadian shareholders, the total tax rate (corporate+personal) is similar to having all revenues to the individual.
That's in theory, of course.
The corporate tax rate is 15% in Canada, 35% in the US.
Bet that 15% makes your nipples hard enough to cut glass.
I would take that bet, but your a welcher.
Slut.
Quote from: CountDeMoney on August 25, 2014, 10:51:53 PM
Bet that 15% makes your nipples hard enough to cut glass.
But would he trade the 35% to 15% for free health care? :P
Quote from: Admiral Yi on August 25, 2014, 10:50:22 PM
Quote from: viper37 on August 25, 2014, 10:45:54 PM
Not really. Tax rates are adjusted, for dividends, mainly. That way, in theory, for a Canadian business and a Canadian shareholders, the total tax rate (corporate+personal) is similar to having all revenues to the individual.
That's in theory, of course.
The corporate tax rate is 15% in Canada, 35% in the US.
talking internal border only.
First, Corporate tax rate of 15% is only for Federal government. You need to add provincial rates, 12% for Ontario. That means 27%.
So, you got 27% for corporate income, then dividend tax rates varies greatly, but if you qualify for all credits, it can be 0%. For most people, it would be around 15% max. That makes 42% for the higher bracket.
Highest total tax rate would be somewhere around 43-45% if you were receving all your revenues in form of wages, at the highest scale.
Canadian corporate tax rates (http://www.kpmg.com/Ca/en/IssuesAndInsights/ArticlesPublications/TaxRates/Federal-And-Provincialterritorial-Tax-Rates-For-Income-Earned-Gen-Corp-2014-V2.pdf)
Unlike US, there are no provinces with zero tax rates for corporations. And IIRC, State tax is deductible from Federal tax? And stock options are qualified as an expense under US tax laws?
Quote from: viper37 on August 25, 2014, 11:46:59 PM
Canadian corporate tax rates (http://www.kpmg.com/Ca/en/IssuesAndInsights/ArticlesPublications/TaxRates/Federal-And-Provincialterritorial-Tax-Rates-For-Income-Earned-Gen-Corp-2014-V2.pdf)
Unlike US, there are no provinces with zero tax rates for corporations. And IIRC, State tax is deductible from Federal tax? And stock options are qualified as an expense under US tax laws?
State taxes are deductible. Some stock options qualify as a deduction, but in those cases the employee must pay taxes.
The biggest difference isn't that Canada has lower tax rates, but that Canada doesn't tax worldwide income.
Quote from: Malthus on August 25, 2014, 03:05:55 PM
Quote from: Tonitrus on August 25, 2014, 03:02:47 PM
For most military bases, the singular fast food restaurant on base is a BK. :(
All your base are belong to us.
:D
:( I wish I'd said that.
Derfetus prefers to eat at Willie Horton's.
(https://languish.org/forums/proxy.php?request=http%3A%2F%2Fi653.photobucket.com%2Falbums%2Fuu256%2Fderspiess42%2FIMG_107047215601591_zps75c87be3.jpeg%3Ft%3D1409060392%3F922&hash=86a33af72b5e6921fc4c7ba2b3c10d1f53a66ff9)
I take it that in Canada, Burger King will be represented by a Burger Governor General?
US ever think about not being a tax hell?
Quote from: The Brain on August 26, 2014, 09:58:47 AM
US ever think about not being a tax hell?
Nah, I think most multinationals are too patriotic to move business off shore to avoid taxes, and those that are not will probably remember their love for America after another speech or two from politicans.
Quote from: Malthus on August 26, 2014, 09:33:06 AM
I take it that in Canada, Burger King will be represented by a Burger Governor General?
Hopefully that wouldn't prevent Mayor McCheese from winning the upcoming mayoral election in Toronto and restoring some dignity to that office.
Quote from: derspiess on August 26, 2014, 11:02:00 AM
Quote from: Malthus on August 26, 2014, 09:33:06 AM
I take it that in Canada, Burger King will be represented by a Burger Governor General?
Hopefully that wouldn't prevent Mayor McCheese from winning the upcoming mayoral election in Toronto and restoring some dignity to that office.
Consign the current one to the deep frier and we will all be the happier for it. :D
Quote from: derspiess on August 26, 2014, 08:49:49 AM
(https://languish.org/forums/proxy.php?request=http%3A%2F%2Fi653.photobucket.com%2Falbums%2Fuu256%2Fderspiess42%2FIMG_107047215601591_zps75c87be3.jpeg%3Ft%3D1409060392%3F922&hash=86a33af72b5e6921fc4c7ba2b3c10d1f53a66ff9)
Is that the actress, the Irish one?
I think this "buy out" makes perfect sense. Now the worst burger place in the world can sell the worst coffee. Deal made in heaven.
Quote from: Josephus on August 26, 2014, 06:10:08 PM
I think this "buy out" makes perfect sense. Now the worst burger place in the world can sell the worst coffee. Deal made in heaven.
You've clearly never had McDonald's burgers or In 'n Out Burgers fries.
Quote from: Josephus on August 26, 2014, 06:09:05 PM
Quote from: derspiess on August 26, 2014, 08:49:49 AM
(https://languish.org/forums/proxy.php?request=http%3A%2F%2Fi653.photobucket.com%2Falbums%2Fuu256%2Fderspiess42%2FIMG_107047215601591_zps75c87be3.jpeg%3Ft%3D1409060392%3F922&hash=86a33af72b5e6921fc4c7ba2b3c10d1f53a66ff9)
Is that the actress, the Irish one?
No, but I wish she lived in Ireland. That is Ms. Sandra Fluke, who didn't have $4 to buy whore pills but did find the $1,000 for the filing fee to run for Congress.
I wouldn't fuck her if you paid me a thousand. What an ugly woman.
Quote from: alfred russel on August 26, 2014, 12:30:33 AM
Quote from: viper37 on August 25, 2014, 11:46:59 PM
Canadian corporate tax rates (http://www.kpmg.com/Ca/en/IssuesAndInsights/ArticlesPublications/TaxRates/Federal-And-Provincialterritorial-Tax-Rates-For-Income-Earned-Gen-Corp-2014-V2.pdf)
Unlike US, there are no provinces with zero tax rates for corporations. And IIRC, State tax is deductible from Federal tax? And stock options are qualified as an expense under US tax laws?
State taxes are deductible. Some stock options qualify as a deduction, but in those cases the employee must pay taxes.
The biggest difference isn't that Canada has lower tax rates, but that Canada doesn't tax worldwide income.
Looking closer at the situation...
Florida has 0% Personal tax income.
Ontarian residents can get very reduced personal income tax on dividends, sometimes even 0%.
Fiscal conventions means Americans can be taxed in Canada or USA.
Doing it this way, Canadian & American shareholders benefit from a reduced corporate tax rate (about 7-8% less) and 0% personal income tax on their dividend revenues for most of the major shareholders. Brilliant move. More dividends, less taxes.
Quote from: derspiess on August 26, 2014, 11:02:00 AM
Hopefully that wouldn't prevent Mayor McCheese from winning the upcoming mayoral election in Toronto and restoring some dignity to that office.
these guys are wise, since the new headoffice will be in Hamilton, IIRC. No silly Ford to mess with them.
Quote from: Ed Anger on August 26, 2014, 06:59:53 PM
I wouldn't fuck her if you paid me a thousand. What an ugly woman.
It's kind of hard to tell from the pic but it looks like she may possibly have nice tits.
Who cares about tits? :rolleyes:
Quote from: Peter Wiggin on August 26, 2014, 06:12:04 PM
Quote from: Josephus on August 26, 2014, 06:10:08 PM
I think this "buy out" makes perfect sense. Now the worst burger place in the world can sell the worst coffee. Deal made in heaven.
You've clearly never had McDonald's burgers
Blaspheme
Quote from: Caliga on August 26, 2014, 08:13:18 PM
Quote from: Ed Anger on August 26, 2014, 08:09:45 PM
Who cares about tits? :rolleyes:
Pistols at dawn.
Why would give monkeybutt the chance to shoot you by wild luck?
Choose knives.
He can't knife-fight.
Choose knives, but then bring a gun. It's the Chicago way.
Quote from: Siege on August 26, 2014, 09:22:20 PM
Quote from: Caliga on August 26, 2014, 08:13:18 PM
Quote from: Ed Anger on August 26, 2014, 08:09:45 PM
Who cares about tits? :rolleyes:
Pistols at dawn.
Why would give monkeybutt the chance to shoot you by wild luck?
Choose knives.
He can't knife-fight.
Don't take fighting tips from a Arab Cal.
In n' out is really the name of a burger place, or is that, like, a joke?
Quote from: Josephus on August 26, 2014, 09:47:41 PM
In n' out is really the name of a burger place, or is that, like, a joke?
Not a joke
Quote from: Josephus on August 26, 2014, 09:47:41 PM
In n' out is really the name of a burger place, or is that, like, a joke?
(https://languish.org/forums/proxy.php?request=http%3A%2F%2Fwww.restaurants.com%2Fblog%2Fwp-content%2Fuploads%2F2012%2F10%2FIn-N-Out.jpg&hash=b15025dae3c698d1079e1fb29891d121ffec0e15)
It's real. But it's referring to the fast food aspect, nothing sexual. :P
And most Californians I have known swear by the place.
I would slot it somewhere between JITB and A&W.
It's fine as long as you don't want french fries with your meal.
Quote from: CountDeMoney on August 26, 2014, 11:45:40 PM
I would slot it somewhere between JITB and A&W.
Fun fact: Canadian A&W is for a variety of reasons completely independent of the American A&W, and is wildly more successful, being Canada's second largest burger fast food chain (Burger King isn't even close).
Oddly, in a number of foreign countries, Burger King is considered a premium product to McDonald's and charges a decent bit more.
Quote from: Barrister on August 26, 2014, 11:54:34 PM
Fun fact: Canadian A&W is for a variety of reasons completely independent of the American A&W, and is wildly more successful, being Canada's second largest burger fast food chain (Burger King isn't even close).
Yeah, we were struck by that on our recent trip. We ate at A&W several times and were impressed. I had forgotten how good they were. I used to be more of a Burger King guy when I lived there because they had poutine(even if it was terribly salty). Now A&W has poutine too and it's quite good.
Quote from: Tonitrus on August 26, 2014, 09:50:59 PM
And most Californians I have known swear by the place.
:hmm:
I don't know. I mean I know a lot of Californians, who originated in other places, who swear by it. I think it's okay but the lack of edible fries is a real issue for me. I'd rather eat at Del Taco.
That said, people certainly do like it in California as else there wouldn't be so many of them in the state. Though I think they are still dwarfed by number of McD's in CA - something like 5:1.
Anyone know the size of the tax savings here? It seems unlikely they are the key driver of this particular deal.
What's A&W?
American and Western?
Quote from: derspiess on August 26, 2014, 08:49:49 AM
(https://languish.org/forums/proxy.php?request=http%3A%2F%2Fi653.photobucket.com%2Falbums%2Fuu256%2Fderspiess42%2FIMG_107047215601591_zps75c87be3.jpeg%3Ft%3D1409060392%3F922&hash=86a33af72b5e6921fc4c7ba2b3c10d1f53a66ff9)
I really don't know.
Quote from: Siege on August 27, 2014, 10:18:50 PM
What's A&W?
American and Western?
QuoteThe company name was taken from the surname initials of partners Roy W. Allen and Frank Wright.
Quote from: Ed Anger on August 26, 2014, 09:49:51 PM
Quote from: Josephus on August 26, 2014, 09:47:41 PM
In n' out is really the name of a burger place, or is that, like, a joke?
Not a joke
And from driving around Anchorage today, there is an "In n' Out Liquor".
Liquor in the front, poker in the rear?
Man, I do miss Jack In The Box. I only sampled it during my visits to CA since for some reason there wasn't none in New York.
JIB is pretty sparse out east.