X ordered to pay €550k to Irish employee fired after yes-or-resign ultimatum

Would this be legal in any jurisdiction (click-or-be-fired)? I am not familiar with US labour laws, are employees actually at the level of indentured servants considering terms of employment (which I would expect to be a contract between TWO parties)?

In the US, in most (all?) jurisdictions, your employer doesn’t really need to have a reason to fire you. They can fire everyone wearing red shirts, if they wanted to.

There are also very few places providing leave (outside of white-collar positions). For example, my wife was given two weeks off from her job after having my son. The state we lived in only required maternity leave to be implemented at companies having more than 50 employees. Oh, and those two weeks were unpaid.

In some places, taking a vacation longer than three weeks requires the company to stop paying your salary and consider you “abandoning” your job, or submitting special paperwork.

I do not miss the US; moving to the EU was the best decision I ever made.

“Unpaid two weeks of matternity leave” are you nuts? Holy sh..

“vacation longer than three weeks requires the company to stop paying your salary” What? Why is it called vacation then, I cannot comprehend this at all, heh.

Don’t tell them some EU companies even give unlimited PAID vacation, lol.
Never experienced this myself, because I usually have “only” 5 weeks paids vacation, but unlimited HO. Of course in practice this means I have main job and also doing self-employed contracts, if work in my main job is done.

I have “unlimited” vacation here in the states. If you go over three weeks, they still require special paperwork, but they allow it if you are tenured enough.

What unlimited means is “as long as your manager is decent, you will maybe get your days off” vs accrued vacation where you may be forced to take vacation to not lose it.

My last office job had unlimited vacation and I never used it (not did most of my coworkers) and at the end of the year you neither had the days taken off nor had you accrued any credit for I taken time.

At the job before that I had accrued 6 weeks of PTO, which was the max. I took every other Friday off after that and was paid out a month and a half when I left the company. Everyone understood the situation, so it wasn’t looked down upon when I was gone every other week.

My perspective was that unlimited PTO was a scam to reduce vacation time. Most people are not going to take advantage of it, so the company benefits.

In addition to not having to pay out at the end of employment, they also do the “unlimited vacation” thing to reduce the liability of unpaid PTO on the books. When our revenue was hit hard in the early days of covid, the company I work for asked everyone to take a week of their PTO to help the financials look better.

> accrued vacation where you may be forced to take vacation to not lose it.

I don’t look at it that way. If you have accrued vacation, you “earned” your vacation and they can’t take it away from you without compensation. Thus, you are guaranteed your days off. If they fire you, they should even have to pay you your salary for those vacation days.

“Unlimited” vacation just gives all the control to your employer: the right to deny you vacation, the right to dictate how long your vacation is, etc.

> If you have accrued vacation, you “earned” your vacation and they can’t take it away from you without compensation… If they fire you, they should even have to pay you your salary for those vacation days.

This is the law in California but not most other states.

In most states, vacation time is a benefit that can expire, evaporate, or be rescinded. The company is just deciding not to assign you job duties during your time off. How generous of them! But it’s totally their right to decide not to do that, or to put a bunch of boxes around how they will do that. So it’s legal, and common, that unused vacation time will actually be lost.

In CA, accrued vacation time is classified as “deferred compensation.” It is legally money that is owed to you. It will be paid at a later date, but it must be paid.

It strikes me as no coincidence that the “unlimited vacation” fad started in tech companies with a large chunk of their workforce in California.

Nebraska goes a step further. Lots of companies have a “use it or lose it” policy for vacation time, so they won’t have a ton of liability on the books. Nebraska courts have declared that vacation time is compensation that can’t be taken away from you, so “lose it” isn’t an option. I worked for a company with half its workforce in Nebraska even though I’m in Minnesota. To comply with the law, the company didn’t pay out your vacation at the end of the year – they locked you out and forced you to take it, now.

It’s highly dependent on company (and team) culture. If you can actually take a generous amount of vacation, personal, and sick (if you need it) time, I have no real problem with it. (Then, I haven’t moved around a lot–I know some people who move jobs every year or two count on a payout from accrued vacation when they do.)

Someone I know who retired from a fairly senior position at Netflix rather liked it and took some fairly long vacations but said there really was a good tradition of umplugging at least as he observed that came from the top.

I don’t really disagree although you can’t really keep people from working on their days off if they want to, at least in a remote/WFH situation.

You most certainly can. I work for a US company where when you’re out on (paid, six month) parental leave, your system access is disabled.

They don’t do that for normal PTO but it’s certainly feasible.

There are a lot of reasons to cut access for people out for an extended period who may not even come back.

Pretty much no one (outside of maybe something regulated who may mandate two week PTOs for security purposes) is going to do that every time an employee takes PTO. In any case, if I really want to do work I don’t even need access to my employer’s computers.

It really depends. The company I work for – doesn’t even have a time-keeping system. Taking vacation is a matter of sending a slack or email, or simply verbally letting your manager and team mates know that you won’t be available. So far this year I’ve taken more than 3 weeks at least. I know it’s not a ton, but the point is – that I don’t know the actual exact count, I strongly suspect that nobody really tracks it in any way, and I am planning to take few weeks more before the next year.

> If you have accrued vacation, you “earned” your vacation and they can’t take it away from you without compensation… If they fire you, they should even have to pay you your salary for those vacation days.

This is indeed the law in Israel. What happens is that people are allowed to accrue a number of vacation days up to a limit, typically however many days of vacation you earn in a year, times two. Then the company forces you to take, at the end of the year, a number of vacation days down to the limit.

Companies where this limit wasn’t put in place introduced a moral hazard, whereby people would wink-and-handshake with their superiors when they would take a reasonable amount of vacation without actually reporting the vacation days to HR, wherein HR didn’t really have the means to detect and enforce against the fraud. Thus people would work for decades, retire, and take compensation for decades of “untaken” vacation days, on top of the normal retirement packages. These policies represented usually $1+ million in obligation per worker and thus were clearly unsustainable without some kind of enforceable limit.

Why would a company allow that, can’t they put a limit on that themselves? All my employment contracts in the Netherlands had a clause about that.

Legacy mistakes from decades ago that cannot be fixed because the employment contracts are collective contracts signed with unions who refuse to introduce limits into new collective contracts.

Since everyone’s discussing the inverse, I shall mention that long ago I worked for a 100 person, 5 year old, startup who’s policy was: your vacation is your year-end bonus. No one could take vacation ever, it just got paid out in December. They did give you Christmas and New Year’s off.

Getting sick was jokingly referred to as a firing offense, though people did take sick leave. Burnout was a real thing – and I barely lasted a year, though that may well have been unrelated.

> If they fire you, they should even have to pay you your salary for those vacation days.

This is required in the US. That’s the point of unlimited vacation – since it doesn’t accrue, the company doesn’t have to pay it out when you leave.

Assuming it is paid vacation, why is the special paperwork required? Governments over here require minimum amounts of vacation out of health concerns, but I can’t imagine how giving away more or even infinite vacation days would concern them as long as the employer is happy with it.

I could see each stint being off for more than 3 weeks would require something from the manager to confirm enough handover has happened. Waiting too 3 weeks is normal each time, but if you’re a project manager and vanish for 5 weeks at a critical part of the project then someone needs to know.

The question would then become why a company would impose such paperwork on itself; but someone else replied that it has to do with unions, which I guess could explain it although it’s still weird.

Working for a 100 year old 5b/year company the amount of forms to fill in to do various things are extreme.

I could easily see a requirement from high up managment to “reduce risk” by having a department have a plan for an unusually long holiday stint (I.e someone taking 6 weeks off in a row), fundamentally because senior management don’t trust middle management.

It’s not actually unlimited. In fact, by not providing a fixed amount, and calling it unlimited, it lets managers put peer pressure onto people into taking less vacations than if they’d made a fixed amount!

To add to that: it also can’t be “banked” (and thereby paid out after departure). Companies give free PTO because real “paid time off” has to be tracked as a liability on their books; if you haven’t “earned” anything and they don’t “credit” you, you aren’t “owed” you anything when you leave/are terminated.

It is unlimited if the employee is talented and good at advocating for themselves.

It isn’t if they are meek or mid.

In general: it’s good to let your employer know that you value your time. If you don’t suck, they’ll respect you more, not less.

It should be called unknown vacation. There’s a limit, you just don’t know where it is.

I assume if you took the UK legal minimum of 5.6 weeks for example, you would get fired.

For those who may not yet know why: US companies must pay out vacation time when employment terminates, meaning unpaid vacation affects liabilities and thus the balance sheet and thus stock price.

We really do not care about caregivers – or kids for that matter – in the US. It’s sad. A lot of talk about “family” and how wonderful kids are yet many companies and politicians fight tooth and nail to make sure people don’t spend time with newborns and otherwise don’t have access to childcare. I don’t have to tell parents in this thread about the “July to August gulf” when all the summer camps end and school is a few weeks away. I am not the only one reading this burning precious PTO just to take care of my kids right now.

Sure. It’s great when people have kids, but the whole scam run by society is to offload most the costs on the parent then tax the shit out the kid once they’re raised, effectively creating a massive wealth transfer system away from working families. Much of the societal issues of how they deal with parents traces back to tragedy of the commons IMO since the kids are future tax stock.

Unlimited vacation is a marketing bullshit. Can I work for 3 months there and go for vacation for another 9 months? Not really. Then it not unlimited.

To have it really unlimited you need a special position, like be a relative of CEO. But in that case you can have the same even with limited vacation policy.

Yeah, it’s just a scam so companies don’t have to keep vacation on their books. It just means if you give your boss enough notice, maybe you’ll get some time off, as long as your project is progressing well.

In most EU countries it is mandatory minimum to give 4 paid weeks off per year, otherwise the company is breaking the law. And maternity leave obviously is almost a year, paid, not 2 weeks unpaid. I find it hard to justify living in a place that cares so little about its people. I get its your home country, but I mean, if your home country is actively hostile towards you, why stay?

> In most EU countries it is mandatory minimum to give 4 paid weeks off per year, otherwise the company is breaking the law.

Make that five weeks for France plus up to 11 days of public holidays. That’s a minimum too, we have a whole bunch of additional stuff that can stack on top of that, so many I can’t even make a complete list from memory.

As per the saying: “The French copy no one and nobody copies the French”. If we were carbon copies of the British or the Americans, life on Earth would be just a little bit more boring.

We’re not better or worse, we’re just different. Deal with it or leave us be.

And enough money to relocate across an ocean, if you can find a job willing to sponsor you, which is not at all assured. And starting a business requires initial capital.

It should be straight up illegal to use the word unlimited in any sort of advertising, marketing materials, job offers etc… if it’s not actually unlimited.

Unlimited paid vacation is simply not a thing that is offered by any company anywhere in the world.

Yeah, I took July off this year and last year. Obviously that needs some up-front notice to ensure there’s cover, but I tell my manager in the spring and it’s fine.

Americans are very, very strange and the fact they think they’re normal is part of that.

There are plenty of US companies that have 4 week vacation policies. There are also plenty with “flexible” time off where in theory you can take more (but tends to converge on some common number).

Probably other US organizations (universities?) also have fairly good vacation policies.

I think what’s different about the US is that the country and states tend to not mandate this stuff. This does lead to people getting exploited under certain situations where the employer has more power in the relationship. I think the US is wrong on this but seems to work for them?

Americans are not “strange”, whatever that means. The US has overall worse protections than the EU, that’s it. It sucks, we all know that. There’s no need to appeal to some weirdness argument.

Presumably, you think we should what? Take the to the streets? Standard of living of food security is still far too high generally for this to seem reasonable for most.

Shall we lobby our representatives? This does happen at the state level, and accordingly many states have more pro-worker policies and laws. But change at the federal level is a substantially harder thing to bring.

Exactly. It’s not a matter of accepting or not accepting. There’s practically nothing that can be done about it.

At the federal level, no major presidential candidate supports EU-style worker protections and mandatory benefits. And not enough congressional candidates support it, not even remotely enough to change anything. In fact, the vast majority are outright hostile to worker rights due to lobbying/capture by corporate interests.

At the state level, there is lots of variance, but even in the states most friendly to workers, it’s not remotely possible to reach Europe’s level of benefits around vacation, sick leave, maternity leave, let alone the right to organize for these things. There is no political will, and any political candidate who actually has the will could never win a statewide election.

The way this worked in many places is that workers formed political parties. In France people did and still take to the streets over labour issues. You can also unionize. Or sure, lobby. But if people are happy with the current system then that’s also fine.

All in all the US has been a success story. Whether there’s correlation or causation between that and some of the regulatory and legal environment is hard to say. Maybe its success is primarily due to resources and geography and maybe the US would be even more successful with a more European style system.

(EDIT: it’s should have been its 😉 )

The fact that this is not happening at a grassroots level in the US would suggest that it’s not as big a deal to Americans as the Europeans in this thread think it should be.

Speaking only for myself, I’ve found that when I joined a company whose time-off policies I didn’t like (only one so far), I just asked for more time off as part of the deal. The response I got was “sure. It’s easier for us to give you more paid time off than more money.”

On the other hand, when I joined a previous employer that (at the time–they improved) had fairly mediocre paid time off policies (not really that bad but it was the first time I had encountered PTO including both vacation and sick time and there was mandatory shutdown around the holidays). When I got what seemed like a pretty generous offer given I was making a relatively small salary at the time and the company was private so no stock, they also made it clear that the PTO was non-negotiable. Now, in practice, given my role no one was eyeing a few hours here and there to go to some appointment or a bit of personal time tacked on to business travel especially if I had traveled over a weekend, but the paper amount of PTO was just so-so.

> The way this worked in many places is that workers formed political parties.

Given the current political system(s) in the US, this is practically impossible at the federal level; difficult at the state level; somewhat more possible at the city level (eg New York City’s Working Families Party). Third parties exist but generally have almost no influence.

My point was that the situation hasn’t reached anywhere near a boiling point for “taking to the streets” to seem wise to the amount of people it would require to bring real change.

I worked at a place where there was a gradually-increasing amount per year you could earn, implemented as a fraction of a day per paycheck. I was earning 5 wks a year when I left. I went on a two-week cruise, and with the usual travel buffers it took three weeks. So now mention of two-week vacations makes me a little nervous.

>”vacation longer than three weeks requires the company to stop paying your salary”

This is nonsense in general. I’ve taken month-long vacations and never had to do anything special so long as I had the time and, obviously, told my manager.

As they said in their comment, FMLA only kicks in for employers with more than 50 employees(technically, 50 employees within a 75 mile radius). States can implement their own laws to extend maternity leave to all employers, but most don’t.

That’s where I suppose the US and EU truly differ. The US generally goes for the “the market will solve it” approach. If you’re a bad employer, nobody wants to work there, the company goes down and the competition wins. It’s a beautiful theory IMHO.

The EU approach is sort of the same, but to add regulation on top to steer the market towards specific goals, like having a strong middle class. If, for example, a company doesn’t suffer from being nasty to their employees (e.g. because they’re a monopolist), regulation will be put in place to create that dynamic. I personally find this approach more feasible, but regulation can be worked around and sometimes backfire, it’s not easy to get right.

Back to your point: It comes down to how much you get paid. If you work full time and can’t afford vacation or sickness, is that OK?

If you think that’s OK, we just disagree I suppose. There’s a power imbalance between employers and employees that favours the employers. They have more money, expertise, legal counsel, negotiation power etc. Given the chance, they will pay as little as they can for labour, crush competition etc. I don’t believe that’s good for a country in the long run.

If you think it’s not OK, something has to happen. Paying people more so they can save up money to deal with this is one approach. Assuming the risk of them not working (with paid vacation and sick days) is another one. In the EU, we tend to go down the latter route. I guess you could see it as patronising, but there is beauty in sharing and distributing personal risks. I’m personally fine with both solutions. I’m running a consultancy right now, so I’ve decided to take the first route, assume and manage my own risks.

I am not sure all these rules are for stronger middle class. I have always thought these are for low-paid workers at a warehouse, cleaning the streets, or alike. They are way more replaceable than some specialist. Yet the state offers protection for their time off which they deserve.

Yeah, maybe that was a bad example, I just meant that the government has certain goals for society and uses regulation to steer the market towards meeting them.

Historically, that stuff was put in place for factory workers in the industrial revolution I presume, though I’m very fuzzy on that. I’d argue good living conditions for low level workers help create a strong middle class through upward social mobility, but that’s going off on a tangent perhaps.

A company having a monopoly on the labor market wouldn’t be called a company, that’s a collectivist state.

A company having a monopoly in the regular market doesn’t really matter for employment: if you’re terrible to your employees, it’s not your customers you have to fear, it’s the employees. They will leave and no new ones will join and you won’t be doing any business if you don’t have any employees to actually do the work you’ll get paid for.

> I guess you could see it as patronising, but there is beauty in sharing and distributing personal risks.

But that’s quite literally what insurance is made for. The only difference is that insurance adds some amount of accountability.

> A company having a monopoly in the regular market doesn’t really matter for employment: if you’re terrible to your employees, it’s not your customers you have to fear, it’s the employees. They will leave and no new ones will join and you won’t be doing any business if you don’t have any employees to actually do the work you’ll get paid for.

Depends on the situation I suppose. If there’s only one bakery corporation in your country and you’re a baker, you can either work there, learn a new job or leave the country. It’s a bit orthogonal for sure, but competition for talent is vital for good conditions for workers. Plus, a monopoly doesn’t have to provide a good product or service, they just use their power to stifle competition. Suddenly their need for competent staff is greatly reduced.

> But that’s quite literally what insurance is made for. The only difference is that insurance adds some amount of accountability

In my book, insurance is for unlikely, expensive events. In Germany for example, if an employee is sick for more than six weeks, the company no longer pays their salary, the health insurance takes over. It’s likely that an employee is sick for a couple of days, not a case for insurance. Just how it’s likely that an employee will want some vacation, also not a case for insurance.

I could however picture a system where companies only pay for the work employees actually do, and the funding for paid time off and sick days comes from some other source. Sounds intriguing. I believe everybody should be able to take some time off work for leisure and sickness, I see that as a human right. How exactly that’s achieved, I’m personally very flexible there.

beauty in sharing and distributing personal risks

That’s socialism. Look at what happened to the USSR and it’s obvious that we don’t want to go (further) down that path.

The cost of living is too high in many places; but that’s a symptom and not a cause.

Um. If you are talking about the US, you realize it has more “socialism” than most EU countries?

– Do you choose your water company?

– How about your power company?

– TV?

– Internet? and can it be different than your TV?

– Cell?

There are probably more that I have forgotten to mention. But, at least where I live, there is a choice for every one of those items. And hey, there’s also no Comcast here.

> “…vacation longer than three weeks requires the company to stop paying your salary and consider you “abandoning” your job”

Can you explain more about your experience with this? I’ve never heard of it.

You begin by referring to at-will employment, which has a long history in state laws. This context gives the impression the “what” that is doing the “requiring” is the state and its laws.

I’m wondering if this “long vacation” thing has a basis in law or possibly originates from individual company or union contracts.

Or if this is a cost savings measure for business services which are paid on monthly basis. Most insurances are based on employee count and earnings, but are calculated yearly.

https://en.m.wikipedia.org/wiki/At-will_employment

I wonder if the development of maternity leave sort of happened backwards from how we typically think of it happening.

Like most people talk about it as if culturally we used to expect 0 accommodations for working mothers, which was bad, and the expectation has increased over time.

But, actually in the past the mother would have spent many dedicated years with the infant/baby/toddler/child, until they entered school. If the mother has multiple children, it’s not really practical for a company to hold their spot open for like 8 years and I don’t think this happens even in the most progressive of European countries.

So, culturally speaking, does the rise of maternity leave actually come from an increasing cultural tolerance for the mother spending less time with the child via daycare?

> If the mother has multiple children, it’s not really practical for a company to hold their spot open for like 8 years and I don’t think this happens even in the most progressive of European countries.

Almost no one in Europe has 8 children but I know women who went on maternity leave 3 times. Generally kills your career as you don‘t advance during those years (and most only work part time afterwards) but the original job is still there.

Especially in very large companies, it‘s not too big of a burden. Just some extra slack in headcount planning. It‘s pretty rough in smaller companies. I used to sit on the board of pre-school. 5-6 employees, all women, lots of pregnancies and with the added twist that if they didn‘t have certain childhood diseases or vaccinations, they weren‘t allowed to work the entire pregnancy. We had to hire a lot of folks on temporary contracts.

Worth pointing out, while we had to pay the salary in case of work not being permitted and the time no work is allowed for anyone pregnant (6 weeks before birth and 8 weeks after), this is fully reimbursed trough insurance schemes every company has to pay into.

> Almost no one in Europe has 8 children

You don’t need 8 children to get to 8 years of dedicated child care with the pre-daycare-normalization worldview. You only need 2 children with an offset of 3 years, or 3 children with less offset.

Fair point, I‘ve been considering todays standard of one year off for each child.

That said, at least in Germany, you can‘t get to 8 years with 2 children as the maximum time for parental leave is capped at 36 months per child.

> your employer doesn’t really need to have a reason to fire you.

IIRC it’s much safer not to provide any either — except in Montana which I believe requires Just Cause after probation, as there are only a handful of statutory exceptions to at-will employment, and most of them are very, very hard to prove without an extensive paper trail… or the employer spelling it out when they fire you.

> In the US, in most (all?) jurisdictions, your employer doesn’t really need to have a reason to fire you. They can fire everyone wearing red shirts, if they wanted to.

This is not entirely correct.

They can fire you for any reason as long as it’s not because of a protected reason.

There are certain protected reasons at the federal level and many states add additional ones at the state level.

So, for example, they can fire you for wearing a red shirt, but they cannot fire you for being too old (well, too old is defined as above 40…if you’re 35 they can legally fire you for being too old if they want).

Question: So what stops them firing the old bloke, simply because they are wearing a red shirt?

Ergo: Surely it should be the other way around; that you can only be fired for specific protracted reasons, i.e. gross negligence.

> Question: So what stops them firing the old bloke, simply because they are wearing a red shirt?

The possibility of a lawsuit, resulting in fines and penalties. Obviously many people won’t bother to sue, and some companies will take the risk.

In some places, taking a vacation longer than three weeks requires the company to stop paying your salary and consider you “abandoning” your job, or submitting special paperwork.

Possibly in Europe, but this not the law anywhere in the U.S.

To the extent that any American corporation requires this, it is purely a corporate policy.

While there are certainly insane laws and regulation in the US, I’m not sure I understand what would even possess a government to require such a thing. I mean, some companies even have paid sabbaticals even if they’re not common. That certainly would seem like totally inappropriate meddling into company benefits for no good reason.

I’d understand (though not agree with) an individual company capping an individual vacation at three weeks, but not a (presumably) state law to that effect.

My god, what a horrible life.

My wife currently has 18 months fully paid maternity leave, and we’re having tons of family adventure with our little one who is already 9 months old.

I couldn’t imagine not having that family time.

Yeah, I think people forget that when you are employed you are not the owner, you are sacrificing your freedom to serve someone else’s enterprise.

I think its very healthy and human to understand people have phases in life where they need to be cared for.

It’s very easy to have a narrow view of the world where everything would be fixed by the ‘market’.

One caveat: at will employment doesn’t allow a company to fire you for “any” reason. It allows you to be fired for “no” reason.

So, if a company says “we’re firing everyone wearing red shirts”, then you can potentially contest that. If they fire you without a reason, then it’s legal. If you can prove there was actually a reason, and that the reason was illegal, then you can sue them for wrongful termination

In this case “red shirts” isn’t an illegal reason for firing because people in red shirts are not a covered class. You can fire for any reason except those related to covered classes so it’s fine to fire with reasons. “You stole from us so you’re fired!” isn’t any risk because people who steal are not part of a protected class.

> “You stole from us so you’re fired!” isn’t any risk

Sure, it is a risk. You could be wrong and then they sue you. Now you have to prove it. Better to just say that you’re firing them and that is all. If they don’t know the reason, they can’t effectively sue you.

> The state we lived in only required maternity leave to be implemented at companies having more than 50 employees. Oh, and those two weeks were unpaid.

Likely the only reason for this minimal amount of statutory leave is a federal law:

https://www.dol.gov/agencies/whd/fmla

Though it does mandate twelve weeks of unpaid leave, not two, but it only kicks in if you’ve worked there for a year already.

> I do not miss the US; moving to the EU was the best decision I ever made.

I agree. I work for a FAANG and could ask for a transfer, but I’m worried about the risks that come with the US labor law and the lack of paid holiday too. Also the waves of lay off were much harsher in the US. That being said, it’s fun to live in a different country (I lived in the US in the past) and there are more opportunities in tech in the US so I’m still contemplating it.

Do you get a US salary? What I’ve heard is that the same company pays much lower wages in the EU than in the US. (With the EU job coming with more non wage amenities like paid vacation, maternity leave, as discussed, and guaranteed healthcare and better public infrastructure.) But I have no personal data point.

levels.fyi contains salary information for comparison.

Take a Google L4 – $280K US, $190K UK, $160K DE.

But when you include the regulatory protections and benefits, the differences in living standards, etc. the US salary is probably still higher but these salaries are certainly nothing to balk at.

Yes, these numbers seem accurate. In my personal case, I could save a bit more (very roughly 20%?) in the US, but I’ve concluded that it wasn’t worth it.

However, for higher levels (L6+), I think the difference becomes more important. Also, in US tech centers, there are many more opportunities than in Europe. If I were to lose my FAANG job, there would be no way I’d make the same amount of money in a different company in my country. On the other hand, being on a transfer visa in the US can make it hard to switch to a different company too.

In the end, there are pros and cons, and not a definite answer as to where it’s best. It depends highly on individual circumstances.

Something to keep in mind on the maternity leave front…

Most short term disability insurance actually covers maternity leave for about 6 weeks. It’s really easy for employers to make sure this is part of their benefits package these days.

While that might seem generous in the US that is not universal and still woefully minimal. All fathers in Canada are entitled to a minimum of 5 weeks of leave let alone the maximum of 18 months leave mothers

> For example, my wife was given two weeks off from her job after having my son. The state we lived in only required maternity leave to be implemented at companies having more than 50 employees. Oh, and those two weeks were unpaid.

Man this is fucking terrible. Despite what someone’s ideas about work might be, this is just not right unless you put work above literally everything else.

I believe this stunt by Elon still doesn’t work in the states. It’s true that if you don’t sign, they are entitled to fire you, but their line that it’s a voluntary resignation is still bullshit. The consequences are smaller, but they’ve managed to do something that doesn’t even make sense in terms of US labor law.

> I do not miss the US; moving to the EU was the best decision I ever made.

It’s very easy to live in the EU with an US compensation.

I wonder if you will feel the same if you had a local job.

Cost of living is also lower here in the EU so it’s not a big deal.

And money isn’t that relevant anyway. Quality of life is more important. That’s why I live in Spain where I make about half of what I could make in Holland where I’m from.

The biggest party in Holland for the last 20 years (VVD) was very neoliberal and they wanted to make the country into America where money trumps everything so I got disenfranchised and left. And right now the biggest party is even extreme right (and supported by the neolibs) so I’m extra glad I left.

But I’m happy in Spain. People enjoy life much more. There’s no calvinist influence. Not to mention the climate.

> There’s no calvinist influence.

You traded the Calvinist influence for the Roman Catholic influence in Spain. I’m sure there are tradeoffs involved. For instance, Dutch people tend to be very direct and matter-of-fact in their criticism of anything, which has benefits w/r/t efficiency and public order. Kind of hard to pull that off in a Catholic country.

Yeah the “at will” employment. It’s terrible. I could never deal with that. I’m really glad for all our social protections here and it’s worth the money.

Also socialized healthcare <3

Bear in mind that it works both ways. I can be offered a new job tomorrow and give my current employer immediate notice that I’m never coming back.

Regardless of at-will employment, the vast majority of employers will still give you plenty of warning before you’re fired for performance reasons. It’s mainly an issue when a company suddenly has large layoffs. And despite what you see in the media, most people are employed by smaller companies that are generally not laying anyone off.

IOW, the negative aspects of at-will employment really don’t have much impact on the average techie’s life.

> IOW, the negative aspects of at-will employment really don’t have much impact on the average techie’s life.

It would for me. It would be a constant worry, being jobless from one day to the next, how to pay the mortgage etc? I would find that a huge negative, even if it doesn’t actually end up happening.

Also besides the notice period you’re also entitled to a significant fee when you get fired (up to about a year’s worth of salary depending on how long you worked for the company). Which is really reassuring especially for paying mortgage etc. I don’t want to live on the edge of my seat all the time. And it’s also something that stops me from moving to another job because I would have to start from zero and lose this protection. Which I don’t mind, I don’t like job-hopping anyway.

I really don’t like the American mentality of high-risk, high-reward. I don’t care much about money but I do care a lot about stability. But anyway I live in Europe and I’m happy with the way things are here. I do hate the neoliberals here that try to make europe like America (which mainly benefits the big corpos, not us).

so now you’ve taken your savings from higher American income and lower taxes and are feeling and bidding up prices for European locals?

Yes, you can be layered off a lot easier in the USA, but you also can jump around and chase higher income that isn’t regulated by the government.

The problem with your perspective is that people in America still want to make 30-50% more than in Europe for the same job and they want to pay 20% less taxes, but they also want all kinds of services and protection.

So I will go out on a limb and guess you are so self-righteous because you have a large savings pool, so you tell yourself “I don’t mind paying higher taxes and making less money because I have security” … largely because you have your savings, which you are also using to make life for Europeans unaffordable but bidding up prices.

> are employees actually at the level of indentured servants (which I would expect to be a contract between TWO parties)

no, it’s actually the polar opposite of that. either party is free to end the relationship at any time. there is essentially what is a long term contract (may not be called a contract), but one which either of the two parties can terminate. it’s halfway between being a european style employee and being a truly independent contractor. an indentured servant is certainly not free at all to end a bad relationship or to seek a better job or more pay – totally the opposite thing.

and i don’t think there’s anything wrong with it. in fact, i personally strongly want to move more toward becoming a true independent contractor someday, but the culture of engineering strongly favors employees for what i prefer to do. i’d rather pay my own taxes and handle my own retirement and medical insurance and other “benefits”, many of which do not benefit me at all.

when you say “click-or-be-fired” it seems shocking. rephrase it into “agree to our new terms going forward, or we will not renew”. i have zero problem with that if that was the situation that was originally agreed to.

now, i don’t know what those new terms are or whether they were fair, and that might have been a problem. but simply the at-will employment system isn’t wrong on it’s own. but in our jurisdiction, not ireland (which is how X appears to have got itself in trouble).

If this was a conversation between equals, I think you might have a point, but the balance of power between employee and employer (especially when it’s a huge corporation) lies firmly on the side of the employer.

An employee has needs that sometimes cannot go untended, s/he has rent/mortgage payments, s/he may have family to take care of, loan repayments, children at non-free school, etc etc. This is normal, and the paraphernalia of living a life. They are long-term commitments.

So if the employee is presented with an ultimatum like this, it really amounts to “rip up your life, or take the new (worse) offer we are giving you”. It smacks of Vader’s famous line: “I am altering the deal. Pray that I don’t alter it any further”. You may prefer living in a world where corporations can wreak havoc with employees lives without consequence (like Vader) but I don’t.

Leaving the country at the end of this year and returning back to the UK. I came here for the money and the weather. The weather is now too damn hot, and I’ve made enough money to retire (in the UK at least) and look after my wife after an American hospital utterly destroyed her life, putting her into a coma after trying to “turn beds” like restaurants “turn tables”. I so much wish I’d done this 2 years ago, life would have been very different if I had.

all of that is fine, but my point and what i was responding to is that comparing the US system to “indentured servitude” is completely the opposite of a good analogy to what it is.

you prefer “guarantees”. that’s fine. i prefer more freedom and i don’t want or trust those guarantees. nothing keeps a company from going out of business and then it doesn’t matter what the law says or what they owed you – piff – you’re screwed right then and there. you can also be run over by a bus tomorrow through no fault of your own in spite of any number of laws to keep that from happening.

> You may prefer living in a world where corporations can wreak havoc with employees lives without consequence (like Vader) but I don’t.

i don’t like that either. but realize we both already do live in that world. unfortunately it is a fundamental universal fact of life that enough power and money can be, and usually will be, wielded to do bad things. since you can’t fundamentally change that, most “fixes” are just trading one thing for another, or shifting costs to someone else, who is probably poorer and less powerful. every safety net is also a set of handcuffs. every benefit has a cost somewhere else. to move more toward more employment guarantees makes you more of a slave, not less. ironically, more regulation strongly favors the larger bureaucracies and bigger companies at the expense of the individuals and small companies. so now you just encouraged more economic asymmetry.

i’m not telling you what you prefer or what’s best for you or what to believe. just realize that everyone does not have the same viewpoint or needs at all. and it’s not simply evil vs. good as portrayed in the movies.

i’m sorry to hear about your wife. the quality of healthcare in this country can be highly variable, it’s certainly not always bad. i’ve heard that UK sometimes has different issues. use your intelligence to make the wisest and best decisions you can and be as proactive as possible, that’s all you can do, anywhere, anytime.

> i prefer more freedom

“Accept this employment contact change or be unable to afford treatment for your illness” is often not really a choice. It’s “freedom” for those with money, oppression for those without.

> nothing keeps a company from going out of business and then it doesn’t matter what the law says or what they owed you – piff – you’re screwed right then and there. you can also be run over by a bus tomorrow through no fault of your own in spite of any number of laws to keep that from happening.

You seem to refute your own point. It’s true you could get ran over by a bus – so why do we still have laws to prohibit bus drivers from knowingly running you over? Because we typically want to minimize the number of lives we “screw”, even if we can’t reduce it to zero.

Further, a company going out of business is still very much in the realm of something sufficient social safety nets can help with – lessening the blow to employees’ lives while they search/train for a new job.

> i don’t like that either. but realize we both already do live in that world.

We can and should try to improve it. There is no reason to be resigned to the idea that this is how things must always be, when this itself is a relatively recent state of affairs and already a notable improvement over, say, feudalism of the 10th century (in both freedom and quality of life).

> every benefit has a cost somewhere else

Humanity’s progress isn’t a zero-sum game – there are plenty of net positive changes we have made and can continue to make.

> and it’s not simply evil vs. good as portrayed in the movies.

I found spacedcowboy’s consideration of power dynamics a significantly more developed worldview than what you’ve demonstrated above.

An interesting facet of a universal healthcare system is how much it could increase competition due to relieving healthcare costs for SMBs and for manufacturing industries like automotive by removing their healthcare obligations.

You actually net increase the ability of people to work for themselves. Healthcare is often cited as one of the primarily reasons people don’t take the step to found their own business.

Not to mention that if you want more equity between employer / employee relationships we need more ways to break up the asymmetric leverage of the relationship and this is a major one that traps folks

Considering the salaries of software engineers healthcare costs in the US are way cheaper than most EU countries. Also, you don’t have to wait months to see a doctor.

this is a good point. there really used to be two major items that were part of this asymmetric leverage. one of them, retirement plans, have started to disappear, and that’s a good thing.

– as you mentioned health insurance (and to some extent life insurance, cheap when young, but not so cheap as you get older)

– retirement. this seems to be steadily changing to 401K type schemes. the 85 point (age + years of service = 85) pensions are solidly in the rear view mirror, and i for one, applaud that. you can take your 401K where-ever you want and decide for yourself what age and how much money you need.

but i have other problems with “universal” health care though; the VA has something like this and it’s not better. must it be that way? maybe not, but is it likely be that way? yeah…

then you have the free-rider problem vs. basic human rights. i’d just be happy if everybody could purchase the same insurance at the same price employed or not if they wished to do so. it’s not quite there yet, although i have received quotes from Kaiser in CA for equivalent individual policies are that are nearly the same price to what just my parole deduction portion is from $$big$$corp – not counting their ~40-50% portion. which implies, as usual, big companies are being not very efficient. billing is a disaster; why is my insurance charged $50,000 for something i can buy out-of-pocket for $5,000? patents and drug companies are a disaster; problem: drugs are too expensive – solution: give artificial monopolies…

so what we’ve done so far in this country manages is a half-measure that manages to be worse than what we had before and just as bad or worse than some ideal universal health care would be. i acknowledge that health care is a thorny problem, nothing seems to be a good answer and we’re highly unlikely to be fixing it (by fix, i mean make it better, not just doing more stupid stuff).

> and i don’t think there’s anything wrong with it.

except all the legal ways you can’t fire someone. Sexism, Racism, Ageism, and maybe Sexual Orientation (may not be Federal) are the big 4 reasons why this can’t simply be a social contract. And there’s more subtle but not illegal ways you can screw yourself over like Promissary Estoppel, because you can’t just hire someone and fire them the first week “for whatever reason” and think that’s not open for abuse.

>when you say “click-or-be-fired” it seems shocking. rephrase it into “agree to our new terms going forward, or we will not renew”. i have zero problem with that if that was the situation that was originally agreed to.

“I have altered the terms, pray I do not alter it further”.

These aren’t even labor laws. This can be extortion or retaliation. Neither of which are exactly squeaky clean. Or it could be a simply breaking of contract (e.g. your contract says WFH and now they want to force RTO you). If there’s no protection nor reparation on the employer side for breaking a contract they can remake at anytime, it may as well be handcuffs instead.

From Wikipedia:

> In United States labor law, at-will employment is an employer’s ability to dismiss an employee for any reason (that is, without having to establish “just cause” for termination), and without warning,(1) as long as the reason is not illegal (e.g. firing because of the employee’s gender, sexual orientation, race, religion, or disability status). When an employee is acknowledged as being hired “at will”, courts deny the employee any claim for loss resulting from the dismissal.

Not a lawyer but broadly most forms of employment in the US is considered to be ‘at will’ and can be terminated by either party at any time for most any reason (excluding membership of a protected class). If you were fired for failing to respond to the yes-or-resign I believe you would be able to claim unemployment because they can’t force you to resign and changing the terms of employment to force a resignation is a ‘constructive dismissal’. American employers tend to be big fans of lying and hoping you don’t know your rights though, or denying valid unemployment claims because they know not everyone will contest it.

Some people do have employment contracts with more consideration but as I understand it that mostly applies to union work and C suite executive positions.

To claim unemployment is to take advantage of Unemployment Insurance. Companies pay into that and when you are terminated (doesn’t count if fired for cause) you get some predefined amount of money for a period of time to help while job searching. The amount is dramatically less than your normal pay.

Unemployment insurance is a form of insurance in US that pays you if you lose your job due to layoffs and other conditions. It is paid by you so it is not “welfare.” It is managed by each state independently and has some rules. For example, if you lose you job today and “don’t claim” unemployment insurance for two weeks, those two weeks are not paid out to you (this is in Texas). Every week, you must show that you are “actively” looking for a job. You may lose the benefit if you are not, or if a job is available but you decide not to take it. You must report on your efforts to find a job (interviews etc), and must attend some state class about looking for work.

Most states’ unemployment insurance covers up to a maximum benefit per week, and a maximum number of weeks. When I lost my job once, I was paid $325 per week.

At least in my state, the employee does not pay unemployment insurance tax, but the amount the employer pays is usually reported on the paystub. That is, if you are paid $85,000 salary it won’t be reduced by the unemployment tax. However, some economists treat all payroll taxes as effectively paid by the employee out of “total compensation”.

I think this is probably legal in the US, since most employment is “at-will,” meaning both parties can terminate it at any time, for any reason, or for no reason at all (with some specific exceptions that probably wouldn’t apply in this case).

Your employment contract may have terms that override the at-will relationship, in which case the employer has to follow the contract’s terms. You may also be unionized, in which case the union will have negotiated termination procedures with your employer. And you may live in a State that has additional rules for terminating contracts.

But as a general rule, I believe this is legal in the US in most cases.

From everything I read, in US, in general, outside of specific list of protected reasons, or a contract specifically describing conditions for contact termination, one can be fired at any time. This works both ways – employee can quit any time too. I wouldn’t be surprised musk just applied the same logic worldwide and let lawyers deal with consequences

“This works both ways – employee can quit any time too.”

I think employees have been allowed to quit at any time since the early 20th century in most western countries. Of course there is a probationary period involved, but it’s nothing like earlier times when police would possibly come and take you to your place of work, or it was illegal to be unemployed in several jurisdictions up to 20th century (e.g. USSR) etc.

So discussing this as “feature” rather than tablestakes in any modern society is somewhat misleading IMO.

I don’t know if there are some professions where it’s a bit more complicated than this and am happy to be corrected.

When I worked in Europe I had to give 3 months notice. If I left before that I had to pay the company the equivalent salary.

So let’s say I leave after 1 month of giving notice. I now owe the employer 2 months salary.

Which country was that (as it doesn’t feel real)? Due to power imbalance the employee is virtually never obliged to pay anything aside cases of disciplinary actions/malpractice.

N=1, here.
Where i am it’s 2 weeks and has to be declared online (so the employee can’t withdraw it, without the boss agreeing to keep them on).

2 weeks in der EU is common, 1 month rarer…3 is a lot and leads me to believe there’s a lot of € at stake in this case.

Three months notice is usual for long term employees in both Norway and the UK in my experience. The employee can of course give notice without any reason but the employer generally has also to demonstrate cause, they can’t fire you just because they feel like it.

For employees that have not been working for the firm very long the notice period will be shorter on both sides. What the exact rules are I’m not sure.

It’s a month here and generally you use up your holidays during this period so it’s generally only 2 weeks or less (we get about a month’s worth of holidays per year here)

Yes this is by law but if the employer is willing it’s always possible to agree to immediate termination. The law is there to protect both sides in case of disagreements only, does not limit otherwise.

It is 3 months notice for me (also in Germany) for either side to quit the contract. However, there are no real consequences if I would just leave without notice. Other than my employer having a bad opinion of me afterward of course.

Like, I could just stop showing up and they would fire me for cause without notice, but that matters only if I needed unemployment pay. If I already had a new job that I would like to start immediately, I could just do that.

> there is a probationary period involved

How is it the same if there’s a probationary period?

I can quit my job today with absolutely no consequences beyond not having an income. Can I do the same where you are?

In (parts of — often state-defined laws) the US it might or might not.

– Generally, you can be fired without any particular reason.

– Outside of a few whitelisted reasons (like being fired “for cause”), when fired, you can collect unemployment (a system where the employer self-insures, sending money into a governmental pool to payout in such cases) for O(1 yr), with caps in the $900/mo.range, depending on the state. Not clicking on the link would likely not count as “cause,” but Twitter might try to argue it does (not that it necessarily matters since the severance package is probably better and probably precludes filing for unemployment).

– Other labor laws exist, like requiring some sort of notification period for mass layoffs. If this were found to be a mass layoff in disguise, there’d be additional penalties.

– Similarly with race or any of the things you can’t fire a person for (e.g., if a person didn’t see the email because they were pregnant and doing something medically relevant, a lawyer might be able to say something about the firing being structured in a way that discriminates against pregnant people, which is not legal).

– If the link had any attached terms and conditions, those likely would not be enforceable since the contract was agreed to under duress.

– Any other contracts between Twitter and the employees might matter. Perhaps the firing is allowed, but there are other constraints on the exact manner (e.g., having previously negotiated a better severance package).

– If the link had any specific terms involving lower pay or reduced benefits or whatnot, there’s a decent chance that it was criminal extortion or blackmail in various parts of the US.

And so on. We can start tacking on hypotheticals which might apply, but I’ll stop there.

> indentured servitude

There’s no need to be so hyperbolic when bagging on the US. It’s bad that we don’t have great safety nets for people, but forcing individual employers to take up the slack isn’t an ideal solution either (still no protections when the employer goes bankrupt or when a crisis hits somebody like a college student, and it disproportionately impacts the smallest businesses because you can’t spread the risk out across a lot of employees and revenue — an imperfect but almost strictly better solution is just raising the unemployment rates to match the real inflation we’ve seen), and it’s nothing like indentured servitude which allows the working conditions to degrade nearly arbitrarily without a chance to leave and go someplace better.

Indentured servants are not paid for their labor. Americans are paid.

The contract is between two parties until a new contract is proposed. If a party declines the new terms (by not clicking) then the past contract becomes void.

There’s a bug in your logic. Yes, if a new contract is proposed and a party declines the terms, there is no new contract. But that has no impact on the old contract.

So the old contract is still in effect, as it was not replaced by a new contract. So who terminated the old contract? That’s the question here, and the conclusion seems to be that the employer is the one who then fired the employee, the employee did not quit by refusing the new contract.

Yes, it would be legal to require an employee to review and sign a new employment agreement or be terminated.

But that’s not what this was about.

X was attempting to characterize the refusal to click as a resignation by the employee rather than a termination by the company. This is because a resignation would not trigger contract-related severance (which apparently Twitter employees had) or hit X’s unemployment insurance account, while a termination would trigger both severance and unemployment.

Right to Work laws, despite the name makes pretty much any firing legal. Unless an employer says something like “You are my least favorite race and for that reason I’m firing you” they’re in the clear.

“Right to work” is an anti union provision and has nothing to do with being fired.

You might be thinking of “at will employment” – which is the case in 49 of 50 states.

In a lot of US jurisdictions there are rules that you have 21 days to review a severance agreement. My guess is that a “you have three days to agree” type notice may run foul of that.

Fwiw…

As a tendency, Irish labour courts tends to find in favour of employees… but also tend to award relatively small compensation.

A headline making award is pretty rare. Judge must not be a Twitter fan.

They have to pay compensation based on salary and tenure time. Most likely the salary in this case was higher than an average Irish salary. Moreover firing without warning tends to increase the severance benefits even more, which is also why it is relatively rare.

I’d assume Ireland has something like bailiffs in the UK.

Delta tried not paying around £3000 owed to a customer. He got a court order and sent bailiffs who went to the airport, closed the checking and said they were going seize the plane to pay for the debt.

There’s a good short documentary about it here: https://www.youtube.com/watch?v=-QSj9odUD_c&t=320s . This link starts at 320 seconds, where the action starts. Start from the beginning if you want the back story.

Spoiler: Delta called the police who explained to them that they were about to pay up or lose the plane. Delta paid up. Actually, the managed used her personal card to pay I’d assume Delta paid her back.

That was amazing, and we absolutely need this kind of enforcement of court ordered judgments in the USA. It’s mind-blowing 1. that Delta fought/ignored to the point where police had to shut down their operations, and 2. how much they even fought back when their counter was already closed down! This corporate mentalities of “We’ll do anything except pay what we owe.” and “We should always be able to throw more lawyers at a problem to delay it.”

Not to mention having the manager pay the police out of her own pocket. Doesn’t Delta have a petty cash policy giving discretion to managers around payments of small amounts like this? The whole thing was both bonkers and very entertaining!

> It’s mind-blowing 1. that Delta fought/ignored to the point where police had to shut down their operations, and 2. how much they even fought back when their counter was already closed down!

All over 3000 euro. For an operation as large as an airline they may as well have been arguing over a dropped penny.

This is one of those “left hand doesn’t talk to the right” situations. Delta has an arm of the company that only deals in disputes and has another arm that does check in and routine services. I think the manager did a good job here – I highly doubt there is a listed provision for allowances like this, but she paid anyways because she understood what the right thing to do was after confirming everything was legit. Unfortunately, companies have to play so defensively because they hold so much power, otherwise people will take advantage and bleed them dry. Note that this isn’t a political comment, I’m not interested in what should be, rather what is. If a company makes an honest mistake, courts will typically side with the less powerful party when possible. For example, JCPenney did a promotion with Firestone back in the day where you could get your car battery replaced for life. The intent of the promo was life of the car, ie 8-12 years, but the language really said “basically forever.” There are people to this day, decades later, still getting free battery replacements(1). Hell, there are people who even hunt for the batteries and make good money when they find them in scrapyards. This promo turned into a perpetuity JCP did not want or intend to have on its books. That mistake went all the way to the top of the company and caused real change in how they did cross promos. I’m willing to bet this delta fiasco went to the CEO’s desk and the company addressed it, one way or another.

(1) https://www.forabodiesonly.com/mopar/threads/jc-penney-lifet…

> companies have to play so defensively because they hold so much power,

You mean they decide to play defensively because they have the power to be a pain in the neck.

>If a company makes an honest mistake, courts will typically side with the less powerful party when possible.

I’m seen way too many malicious “mistakes” punished with a slap on the wrist to really believe this.

First things baliffs typically seize are bank accounts, way less fuss with them than with physical assets. You typically only seize physical assets from broke people, or from companies that went bankrupt.

There’s a strong chance Delta don’t have much legal/fiscal presence in the UK. Probably also why they didn’t feel a pressing need to pay fines in the UK.

There’s a much higher chance that Twitter have a legal and financial presence in Ireland, especially being that it is/was their EMEA HQ.

That video is also a great example of just how abusable the bailiff system is.

All the “agents” care about is getting the money for their client. For this, they’re willing and apparently able to abort at least one flight, and possibly others, costing people on those flights possibly thousands each with rebookings etc, all for £3k.

I’ve only has the displeasure of interacting with a bailiff once, when I was a naive student. The guy knocked on the door asking after a previous tenant. We went through for any mail addressed to the guy he was after, and while doing so seemed to revel in explaining how he had the power to barge in by force and arrest me if we wanted. In the moment I was slightly incredulous but nodded along. Was only after the fact I researched to find you’re within your rights to turn them away unless they’re accompanied by actual police.

Seems like the perfect job for power-tripping sods.

I find it difficult to side with Delta when they’re trying to shirk their legal obligations to their customers.

There’s a comment in the video that this is david vs goliath, and they give david some leverage. I think that’s the perfect use for high-court bailiffs. The other way around, maybe not so much.

(Ironically – obeying court judgements is not without control of the airline, so if this caused delays, those customers could claim compensation also.)

In general I agree, the bailiff system should be abolished for personal debts.

Except these are High Court bailiffs collecting a commercial debt. They just enforce the powers of the court. Useful in this situation where the executives are in a different country. The High Court can do a lot worse than stopping check in if you don’t comply with its orders.

Sure, no problem with their use against companies.

I don’t care about the cost to Delta in that video, but I do think this particlar strongarm tactic was way over the line, due to the significant financial impact it could’ve incurred to innocent bystanders

Years back, a software consultancy owed me money. I took them to court and eventually called in the bailiffs for non-payment.

Are you seriously saying I should not have done this, just because it might have inconvenienced their other customers!

Get a grip sunshine; and put the blame where it it due.

>I don’t care about the cost to Delta in that video

I do. if it was something like 3m euros I’d understand the greed, even if I don’t condone it.

3000? They just seem petty. As the article said, this was something a manager could pay out of pocket (and I hope they got reimbursed). It should have been a rounding error already built into their budget that they paid immediately. Delta clearly didn’t care of the “innocent bystanders” either, or they were willing to bluff with them as ransom. I’ve had delays for stupider reasons, but this would at least be a hilarious story to share as a passenger.

It’s not like some working class that may not have that much in liquid to pay off.

Debt Collector != Court bailiff

You clearly had the former masquerading as latter. In Blighty, a debt collector tricking a naive student into believing they have court authority (!) is their Standard Operating Procedure.

There are two Irish state departments that are hyper competent. The IDA and Revenue. This can involve both. I’m not at all worried or the political blowback will see them functionally banned from Europe and an acceleration of the social media regulation and hate speech laws introduction.

when given 2 choices, people always forget the 3rd default choice of doing nothing. Despite many philosophies, “Doing Nothing” in a legal sense cannot be taken as a Yes or No. Maybe they simply never saw the message in time (especially something as time sensitive as 24 hours).

I am glad to hear that workers rights are being enforced in Europe.

As an employee in Germany, it sounds deranged to receive an email saying I have one day to completely change my work contract, or be fired from my job.

I’m so glad most European countries have robust labour laws which often favour the employee in case of doubt, not the employer.

This type of behaviour – unilaterally changing the employment agreement without even specifying them in their entirety! – should never be possible.

I hope other employees and EU countries follow suit and slap X with more fines, if this impacted other citizens as well.

The problem is that you can still get fooled or bullied into accepting a bad deal. I suggest everyone working in the EU to learn their rights and to consult a lawyer when something doesn’t feel right, doesn’t cost much here, initial consultations are often even free. Don’t sign something put in front of you before you had a chance to understand your position. The person who wants you to sign it had ample time to do that, you didn’t. Same goes for accepting things that seem unfair via email or verbally, that can weaken your position already.

I’ve been on both sides of the fence (mostly in Germany). As an employer, my approach was usually to be nice to employees I wanted to get rid of and to offer them a good severance package proactively. If you push an employee and give them ammunition to sue (and you fail to fool/bully them) it’s gonna get a lot more expensive. Not to mention distracting/emotional. Just keep in mind that if you hire an FTE, you’ll have to mentally put money aside to exit them at some point in the future. Hiring freelancers is more expensive, but doesn’t carry these problems. I tend to mix FTEs and freelancers, partly to distribute the risks and costs.

When talking to people in bad situations with their employer, I’m always surprised how little they know and how easily they’re willing to take the short end of the stick. There’s a deal between you and the company that specifies what you’ll do for them and what you’ll get in return, with legal context surrounding it. I think it’s also good to be nice and willing to compromise in that situation, but employees generally don’t seem to be aware of what a powerful position they’re actually in, and don’t feel they “deserve” that, or don’t want to upset anyone. It’s business at the end of the day, contracts. Don’t be a bad business person, it’s not like CEOs will respect or like you more if you don’t put up a fight. Typically the opposite.

The lack of these protections is one thing that, IMHO, warrants the comparatively high US salaries in tech. More risk, more reward – business 101 stuff.

Not sure about germany or other countries but in France any contractual change that specifically make the employee position worse without any clear return is essentially voided in “prud’hommes” (the workers/companies justice court) unless they were warned in advance of a negociation meet and brought their representative with them (any company above 10 must have one, and more and more as the company grow).

Also, any major change need to be in counter signed writing, it cannot be a one way thing, not even a “we both agreed” even if it’s true.

As an employer myself it sometimes lead to seemingly absurd situation where you need heavy procedures for a simple change, but the end result is that no worker is screwed this way in a way that would stick in court (it still does happen, mostly in areas where people don’t go to court after, of course).

A specific kind of deal is the “the company is going south, we make a collective agreement like eg no firing and no dividends and workers agreed to reduced hours or salary for X months” things like this, and in Twitter case it could be what they should have used, but again these have clear procedures and steps to be considered legal and not abuse by the employer, and as you can imagine a middle of the night email with no representation does not fit at all.

I know Musk is a know it all that believe he is so smart and better that he doesn’t need to listen to the competent persons around, but I wished I could be a fly on the wall in the company’s lawyer room that day, just for the absurdity of it (I imagine it was sort of “we can pretend it’s ok, or we can tell him and be fired too”).

Oh we don’t appear to have that level of protections in Germany. If you accept, for example, a demotion (that one could argue is still in line with the job title and description in your contract) via email, it’s difficult to contest later. If you do want to contest it, you have to be quick and do it in writing. For something like reducing salary or other benefits, or changing your job title, those need to be counter signed. Problem is, quite often promotions are (deliberately) not offered with contract amendments, so when you’re demoted later, the company can argue you’ve never legally been promoted in the first place. Sounds like a drag, but it’s incredibly useful to describe your role and responsibilities in the employment contract, and to insist on an update once promoted.

As for Musk’s lawyers, I’d also love to know how exactly that played out, I can imagine all kinds of scenarios, some hilarious. The most likely to me seems that he wasn’t exactly involved in this particular case, or any of these cases. People handle it based on what they think he’d want to do, then pass on the bad news if their plots fail somehow. I’m assuming this might be net positive for him in the end: He got away with the forced, incredibly quick culture change and workforce culling and was able to move forward with his strategy immediately. Delaying problems seems to have worked out for him quite a bit in the past.

> The problem is that you can still get fooled or bullied into accepting a bad deal. I suggest everyone working in the EU to learn their rights and to consult a lawyer when something doesn’t feel right,

If you’ve been forced to make a choice with an incredibly short timescale, many tribunals/courts (in Europe anyway) will put aside your choice if it later turns out to be detrimental. It’s a bit like forcing someone to sign a contract at gunpoint.

> “I suggest everyone working in the EU to learn their rights and to consult a lawyer when something doesn’t feel right, doesn’t cost much here, initial consultations are often even free”

In many European countries unions provide free legal support.

Join the union even if things are good for you now, and you don’t have to go hunting for legal help if one day you feel like your employer isn’t being fair.

In France it’s mandatory in a company to have a “company union”, after 10 employee it’s one representative (employee who has part of his paid time dedicated to employees support functions, and it grows to more and more the more employees there is.

Whether those representative act on their own, or join a national union or syndicate, is their own decision, and they’re elected every 4 years.

Any meeting or importance between an employee and his employer, he can request one of the representative be present to assist him (and in some type of meeting, it is pretty much mandatory to avoid employer pressuring against).

Etc etc …

Our system is far from perfect, but at least having SOMEONE in the company to turn to seem to make sense to me.

> In France it’s mandatory in a company to have a “company union”, after 10 employee it’s one representative (employee who has part of his paid time dedicated to employees support functions, and it grows to more and more the more employees there is.

In Germany, that’s called “Betriebsrat” (something like “company council”) with pretty much the same purpose.

And then there’s the “Gewerkschaft”, which are unions not for one company but for entire sectors of the economy who – through their numbers of members – are able to do collective bargaining for the employees of their fields of various companies. E.g. “IG Metall” being the industrial union of metalworkers, which considering Germanys large manufacturing background is the largest union in the country.

See also: https://en.wikipedia.org/wiki/IG_Metall

I think that the standard translation into UK English of “Betriebsrat” is “Works Council” (1).

I’ve never been highly convinced by these organs, since they seem to be colonised by folks who want to become Very Difficult to Fire, and who ultimately fold to any poorly thought-through management decision that impacts the lives of employees.

I’ve come to that both as an individual contributor and as a senior manager, but YMMV.

(1) https://en.m.wikipedia.org/wiki/Works_council

Is it wrong for people to voice views that you disagree with? The value of HN is hearing differing view points.

It would be nice if people on HN tried to engage in a good willed nature rather than treating discussions like a struggle session.

But to the topic at hand, in rapidly changing sectors, high levels of friction when it comes to employment has a cost. There is no free lunch in economics.

When hiring employees means you’re hiring them effectively for life, it creates disincentives for hiring. Maybe you hiring consultants instead. Or maybe you make do and not hire at all.

No doubt it benefits employees when it comes to job stability. But the cost can be not having those jobs at all. That’s something that has to be considered in the equation.

The other thing is the employee obligations it creates. When I worked in Europe I had to give three months notice to quit. Either that or pay the company the equivalent of the salary I made. As an employee it was a penalty I couldn’t afford and thus opportunities at start ups that needed someone now were out of reach. Employee protections had a real cost to me.

It’s pretty clear that Europe as a whole is willing to pay that cost, but it’s a choice.

Nothing wrong with that, but one can’t make that choice then turn around and wonder why your innovative sectors are lagging other countries.

The problem on such discussion that many Americans (I am not sure if you are but experience says yes you’re) tend to use only straw man arguments (and that’s why the reason they are ignored)
“When hiring employees means you’re hiring them effectively for life, it creates disincentives for hiring. “

In Germany it is not the case.

“The other thing is the employee obligations it creates. When I worked in Europ”
Europe is a big place and working law in the EU (and outside too!) is in the charge of national law. Where have you been living ?

In Germany you can talk to company to quit earlier because these quitting comworkers tend to be rather unproductive.

The 6th largest Software-Provider in the World (SAP) is probably the most notable global german software firm. Deutsche Telekom, maybe.
As far as I am aware, there are some bigger gaming companies as well.
But this is, of course, a singular counterexample.

Germany has a large “Mittelstand”, so medium sized companies and much stronger antitrust/cartell-laws. One could argue, that the lack of extremly large tech-companies is, for better or worse, by design.

Wirecard was a disaster for a multitude of reasons: The company itself (lost|stole|defrauded) a billion euros, their auditors (Ernst&Young, now “EY”) failed to notice a billion euros of irregularities and lost their auditing license over the debacle. The german banking authorities failed in some capacity I cannot remember right now.

The BaFin regulatory failure was pretty spectacular too, despite the lid that the German establishment tried to put on it. Not so much has leaked out so far, mainly because prosecutors have declined to take much action against the regulator or its employees and officers, however what is known is pretty damning.

First, they ignored early – like TEN YEARS – and relatively continuous warnings about fraud at Wirecard.

Then they legally targeted journalists who pointed out misconduct at Wirecard (!!!)

Then they banned short-sellers from shorting Wirecard (!!!!!!) and indeed in internal memos mentioned that short-sellers were Israelis and British citizens in some kind of bigoted justification for the ban. Gross and disgusting, but perhaps par for the course in some levels of the government there.

They tried to cover up malfeasance within their own org, including at least one, but probably more employees undertaking insider trades on Wirecard before its failure.

But don’t be too worried about the poor chauffeur-driven bureaucrats at BaFin!

They’ve since reorganised and added more senior employees to an already bloated and ineffectual regulator who are culturally in bed with the regulated entities.

The gravy train must continue.

(Just reviewing what happened through internet searches has caused steam to come out of my ears again. What the actual fuck was BaFin doing all those years?)

I don’t know why you are interested in a niche BaaS/Investment bank. The customer facing “fintech” is N26 and they used Wirecard as a BaaS(banking as a service) provider before they had their own banking license. If you are interested in another BaaS then checkout SolarisBank instead.

We also have our own fancy pants multi billion dollar delivery companies like “Delivery Hero/Lieferheld” or Zalando that Silicon Valley types are so fond of.

SoundCloud is a German startup. So is ResearchGate.

Or how about Hello fresh that so many English speaking YouTubers tend to have sponsorships with?

By the way I was mostly trying to think of Silicon Valley esque startups with a strong internet presence. The moment you talk about things like semiconductors, digital twins, robotics, basically any manufacturing related technology, Germany has a long list of major “tech” companies. I know, I know “tech” is actually American slang for software, not hardware, technology but still.

You are literally aware of a single German company and because of this you assume what is true for them is true for all German companies, nay, all of Europe?

lol. The German cope is strong here.

It doesn’t generally get included for the same reason IBM doesn’t typically get included in list of ‘tech companies’, even if they are one of the oldest actual tech companies.

Been around forever (70’s or earlier), large multinational, more about business integration and sales than any headline tech. Frankly, their tech has been a side thought for a very long time internally. It’s a blue chip that happens to involve tech, not a ‘tech company’ like any of the FAANGs. Same issue Tata/Wipro, etc. have IMO. Arguably Oracle falls in the same class too.

A parallel comment mentioned Deutsch Telecom, but they’re really not a ‘tech company’ anymore than T-Mobile, AT&T, Comcast, etc. are.

If we include it anyway, that gives Germany 2 and the US…. Several dozen? Minimum? Maybe 50ish, actually. Even if we don’t use the same broad criteria in the US.

If we use the same broad criteria in the US, probably 1/3 of the Fortune 500 qualify,
if not more. Is Bank of America a ‘tech company’?

> Been around forever (70’s or earlier), large multinational, more about business integration and sales than any headline tech.

This fits Microsoft as well. Are they not in tech?

Hey, I didn’t make the rules.

They always seemed a bit weird to me. Near as I can tell, they were first, bigger, and invented most of the tech at scale (well, kinda – porn companies were first I think?).

Also, without the N in the acronym it becomes a lot less cool sounding, and well, a lot more derogatory.

I’m not sure what gave you the impression that the single example I brought up was meant to be exhaustive.

If you want examples that fit some specific definition of “tech company”, please share that definition, or where one can look it up. I deliberately didn’t bring up more examples than SAP, as I didn’t want to get lost in the weeds.

That is unbelievable to me. You always have the right to quit, and penalties are rare. The laws depend on the country you’re in of course, but I’ve never heard of three months, and I’ve lived in Europe my whole life.

Would you mind sharing the country you were working in?

In Norway, 3 months notice is the norm, and you can be expected to work it. In practice, there’s rarely much value in holding people to it (though it can happen) because someone who really doesn’t want to be there isn’t going to be a productive employee. But lots of people do stay the 3 months because people looking to hire are also used to often having to wait 3 months to get someone on full time.

It’s pretty common to have penalties if you quit without notice.
It’s also a breach of contract. Employers probably won’t go after you in court though, unless your immediate departure cause them some damage larger than the lawyer’s bill.

One month is common for juniors or contractors. I’ve never seen a contract with less than 1 month notice in tech.
Three months is common for senior or management positions.

My previous contract (Ireland) was 3 months – it was reciprocal, so they had to give me 3 months notice to quit, and I had to give them 3 months notice to quit.

Due to the position “garden leave” was the most typical way to spend those 3 months, so it wasn’t much of a real-world concern.

I am Italian and at my previous work at a bank, I had a two month notice (originally one, but increased with seniority). As far as I know, it is pretty common in Italy, and employers know that when they hire someone, the person will only join one to three months later due to this – or sometimes they offer to pay the penalty

In Germany the minimum time of notice for being fired scales up with your seniority (number of years employed in the company). However, many work contracts add a stipulation that the minimum time of notice from the law be applied to both parties equally, so quitting will also need an advance notice of the same length.

Treating workers terribly isn’t considered good startup/innovation culture by the US. It is standard practice by large non-innovative corporations though which is what Twitter is. Twitter surpassed stats that would qualify it as a startup over a decade ago long before Musk entered the picture.

Americans call it innovation I call it going back to 1890.

But I refuse to believe that every employer in the US is a piece of shit. I bet most of them are decent people.

I mean, it does allow a better access to “move fast, innovate and break things”, the issue being that some of things broken are people lives and careers and in the EU we more or less decided this was not ok nor worth it.

Well, stifling regulation is one problem, but the real reason the EU is behind is the lack of a single place with low taxes on investors and talent.

The effect is compounded by all the smart talent going to SV or large rich cities (London, Zurich), leaving scraps to the rest.

Unrealized capital tax gains being reinvested tax free made Silicon Valley’s exponential growth possible (which is the only reason why a16z was forced to back Trump despite the Tech are being overwhelmingly democrat leaning – they’re scared they’ll be taxed out of existance).

The issue in Europe is that in many countries the law goes to the opposite extreme. The level of ‘protection’ and rigidity is so high that it actually utimately hurts people because there are fewer opportunities and lower growth as a result.

BTW in Germany, if a company decides to lay off people just to save money, they have to coordinate with some government agency — and if the company doesn’t have financial trouble, those layoffs can be blocked.

This happened to Alphabet/Google when they wanted to lay off 6% of their workforce, but were wildly profitable. They couldn’t in Germany.

(This probably wouldn’t have applied in the Twitter case, because Twitter wasn’t profitable, but it illustrates that there are processes and rules around employment that might seem very unusual to others).

I know the subtext of this comment is “European labor laws are good.”

But it seems you’ve cited an example of something ironically very anti-labor. This means your government has codified into law the false idea that all human employees are undifferentiated commodities (like cattle). So as an employer, if there’s no ability to remove underperformers every year, you’ve turned employment into a market for lemons, and created a classic adverse selection problem: https://en.wikipedia.org/wiki/The_Market_for_Lemons

A market for lemons 1) suppresses prices (wages in this context) 2) decreases price variance and 3) creates inefficiencies. As 50% of workers are actually above average (statistics!), you’ve created a negative feedback loop hurting workers wages and ultimately growth in the economy.

> But it seems you’ve cited an example of something ironically very anti-labor. This means your government has codified into law the false idea that all human employees are undifferentiated commodities (like cattle). So as an employer, if there’s no ability to remove underperformers every year

No, that is not the case. You can still fire people and you can do so especially if they are underperforming. You just can’t do it as a mass layoff.

If you fire someone then you need a reason to do so. If you fire people because of a layoff then you need to show that the layoff is legitimate.

You can not just group underperformers and let them go as a layoff because you are circumventing labor law. You can not lie about the reason why you are letting someone go.

No one would care if you fired 99% of your company IF you are prepared to show they were underperforming and that was the official reason given.

I was easy enough to fire for my former employers.

You would probably say that it isn’t EASY because in the US it is much easier to do. You might not be able to do it immediately without notice period unless the employee does something really stupid or illegal.

You can however fire someone any time when you give them the notice period defined in the employment contract. You might need to give them a warning that they are underperforming first so that they can fix it before you fire them, but after that, you can just fire them.

This happens ALL THE TIME, but it isn’t done as a mass/group action. If you have a problem with an individual then the individual gets fired.

Also, in the first 6 months, you don’t need any reason and the notice period is shortened to 2 weeks.

you need to define “easily”. No, you cannot just one day walk to an employee and say “you’re fired, effective now”.

But it’s not some multi-year ordeal just to let go of one employee in the EU. Maybe in Asia, but different culture, different sentiments.

> So as an employer, if there’s no ability to remove underperformers every year, you’ve turned employment into a market for lemons

You can fire someone, but not on a whim*. You need to build a file, build history, give chances for one to improve their behaviour and performance.

*in some cases you can, like grave errors, like ignoring safety regulations, endangering others, etc.

>This means your government has codified into law the false idea that all human employees are undifferentiated commodities (like cattle). So as an employer

If layoffs only affected “underperformers” you may have a point. laying off 6% of your workforce despite a profitable year betrays the basic idea of “underperforming”.

All that aside, if your worst employee is still generating a profit for the company then there’s little ground to say they are “underperforming”.

German here. I would be very interested in the government agency you are alluding to.

There are laws regulating layoffs due to operating conditions (Kuendigungsschutzgesetz). But these laws do not allow the government to intervene directly in company affairs – that would be communism! If a company wants to restructure “for internal reasons” (rationalizations are specifically mentioned) it is allowed to do so. This includes offshoring, moving workload to contractors, or simply getting rid of a department.

However: many of the large companies (eg. SAP, BASF, carmakers,…) have collective labor agreements. These agreements often exclude layoffs due to operational conditions within a certain period. Under very special circumstances layoffs are still possible in such arrangements, but the companies have to prove their economic hardship and the layoffs often end with a sort of golden handshake. If they happen at all 🙂

I’ve read up a bit on it, and it seems I was wrong. I was under the impression that some kind of regulatory body that told Google that they don’t have a good enough reason to lay off people, but it might have been their own council.

To lay off somebody, a company needs a reason, and the bar for being laid off because of redundancy is pretty high. You have to be able to proof that either the economic situation is bad enough that other measures don’t help, or that their labor had been automated away, or other possible reasons that don’t apply here (like seasons for seasonal workers).

If “innovation” equals firing a quarter of your company at a moment’s notice because some psychotic C-level wants 3 cents more of profit this quarter, then I’ll take stagnation, thanks.

Frankly, I am European and I know what I’m talking about. It seems obvious that there is a conflict between protecting workers’ rights and giving companies the freedom to decide what’s best for them. On the other hand there is a dearth of dynamic and successful startups in Europe and it’s hard to imagine that workers protection have nothing to do with it- also because in my own country I have seen countless times excessive workers protections slowly suffocate a company, until both the jobs and the entire business are lost.

It’s the main reason I chose to move to Europe instead of the US, despite potentially making more money in the US. I very much appreciate the labor protections in most EU countries.

You are effectively buying those labour protections with the difference in salary.

Companies could even offer that as an option. We pay you $97k with no labour protections, or $68k but we promise to give you all the labour rights that Germany has, including nice long holidays, unions, no unpaid overtime, can’t be fired without cause, etc. Your choice.

(And those figures are the median programmer salary in the USA and Germany respectively)

> You are effectively buying those labour protections with the difference in salary.

Yes. And I appreciate those labor protections enough that I gladly pay for them.

I could still buy a car, a house, raise a family, have some savings, etc.

The stability and security provided by the labor protections are very much appreciated, a lot more than some extra cash would be.

Short term contracts have pretty big downsides though. It’s basically impossible to get a mortgage on a short term contract, or more generally any kind of loan. Even renting is difficult.

That’s why many EU countries have pretty strict limitations on short term contracts, like how many you can do in a row. It results in a huge reliance on contractors.

Short term contracts are basically taking the entirety of the ‘shit’ end of the stick for someone else, and are way worse than the median tech job in the US conditions wise.

nope. you dont invest the same way in a 6 month contractor that you are not sure to renew down the road as you would for a full time employee. And this goes both ways. The contractor has not much incentive to perform well either.

> And this goes both ways. The contractor has not much incentive to perform well either.

Can you explain your thoughts here a bit further? The short term contract can be renewed or replaced with a full time contract. This should provide extra incentive to perform well compared to a full time employee (who doesn’t have to worry about either), as long the as the company is a good employer.

>The short term contract can be renewed or replaced with a full time contract.

As someone in games, this is exactly the road to getting exploited. “If I work harder and really wow them with this feature, I could get full time work!” meanwhile, there were plans to not renew anyone at the end of the project and to lay off full time workers. But you get a convinient carrot to lure starry-eyed devs with

Your “as long as the company is a good employer” is doing Atlas levels of lifing here.

Burn too much good will and people will treat the contract as a contract. And not a hope to impress the boss for a ft role. Another short term exploitation that turns into long term cynicism.

I don’t think that’s happening in games or tech, but it’s been widely observed that Gen Z is less invested in corporate than ever before (or from the boomer’s POV: “nobody wants to work anymore”).

Sadly, that’s what happens when everything is treated as a resource in exchange for short-term gains. Employees, good will, any morals and ethics – all will be sacrificed on the altar of shareholder value.

I’d rather go through a bigger hoop one time every 10 years or more than the current circus of being let go every 2-3 years and needing to re-interview. The latter just means I spend part of my free time worrying about the next job hop by studying trivia, instead of doing something I actually like to do.

Employment figures for Ireland or Germany aren’t far from their US counterpart.

And on the other hand, the French government dramatically loosened the rules around layoffs in 2016 (you can let people go as soon as you have a decline in sales over a few month, a negative cash flow over the same period, if their are new competitors on your market, or even just if there’s technological change in your sector that justifies getting rid of people). It was 8 years ago and it has had little to no impact on France’s unemployment, which is still very high.

> I could still buy a car, a house, raise a family, have some savings, etc.

You are an outlier. Very few SDEs in EU can afford to raise a family in their own SFH on a single salary while living in a location with any notable IT jobs market.

In Poland, it’s not hard. I suspect some other EE countries are similar. Western Europe is harder, with high marginal tax rates and super-expensive real estate.

This actually used not be the case. About six years ago I was in San Francisco for work, and was surprised how inexpensive it was. Like, it wasn’t cheap, but I’d heard it talked up as basically the most expensive place in the world, and it was largely cheaper than Dublin.

Going back recently, it’s a _lot_ more expensive; home has gotten more expensive too, but not at the same rate.

(Some of this is due to the currency thing, of course; the dollar was about as weak as it ever got post-financial crisis in 2018.)

Your mistake there is comparing to Dublin – I live in an expensive Uk city (Edinburgh) and it’s just incredible how expensive going home to Dublin is.

The other bit is that you’re comparing living in Dublin to visiting SF. Rental prices in SF make Dublin seem cheap. You’re still probably financially better off living in SF as an engineer, but I’d rather the quality of life of Ireland/Europe

Oh, sure, like I’m not saying SF was ever _cheap_, but it used to be in the same range of cost as Dublin (a very expensive European city); now it’s way more expensive.

> Rental prices in SF make Dublin seem cheap

Oh, yeah, they definitely do _now_, but pre-Covid it wasn’t as clear-cut.

> You’re still probably financially better off living in SF as an engineer

I think even that probably isn’t totally clear at this stage. If you’re in Big Tech(TM), you’re probably getting on the order of 60-70% pay in Dublin that you’d get in the same role in the same company in Silicon Valley (there’s some variation, but that’s about the usual ratio). If you have to pay SF rent or mortgage (plus property tax) with that, then you may not come ahead. If you can afford to buy outright or with a small mortgage, you’re probably doing better in SF, but even most big tech workers can’t afford that.

(I think the pay gap probably is bigger outside big tech, tho)

> I heard that wges are less than 50% but you end up saving more

Curios regarding how you came up with that conclusion. After paying rent, taxes and buying some groceries from EU senior engineer’s ~80k you will generally have enough to maybe buy a new smartphone at the end of the year, not any meaningful amount of savings.

Honestly, true. But possibly not in the way people imagine

People see the difference in wages, but what they miss is a) the amount of fees and extra expenses they have to pay that escape cost of living calculations, b) the “natural” lifestyle inflation that comes with living in the US (maybe summed up by the word consumerism), c) some size/low density related inefficiencies and d) things like educational costs

Now, yes Europe makes it hard on itself a lot by being dumb (see HS2 costs soaring off or the failed German energy policy – not against renewable but their fee structure is stupid)

> Europe is CHEAP compared to America, it’s fascinating.

Yup. Cost of living is insanely low compared to the US, even when just comparing hotbeds like Silicon Valley vs London/Berlin/Munich, with the largest factor being housing. Additionally, healthcare costs are far lower as well – there is no such thing as co-pays, surprise bills and whatnot here (although I do admit some things like dental and vision care aren’t covered by insurance, but generally still affordable).

Interesting, but as someone who visits the USA sometimes for short work/tourist trips, food and drinks are much cheaper pretty much anywhere except maybe California. And because that’s most of what you spend on during short trips, not counting hotels (which are about the same price as Europe) to me the USA is a paradise of cheap drinks and large meals 😀 (but yeah, Europe wins on quality).

> You are effectively buying those labour protections with the difference in salary.

FWIW, this is not as simple as labour protections being effectively equivalent to $29k. By being a legal requirement and not a choice, that $29k doesn’t register to the market as using disposable income, so competitive pressure doesn’t inflate prices of everything to compensate. It’s strictly better than having a choice between $97k and $68k + labor protections.

Also you are not taxed on that notional 29k, of course (this is one reason that companies often offer in excess of the statutory minimum paid leave etc; it’s essentially an un-taxable benefit). Given the choice between an extra week paid leave at your 100k a year job (notional value is ~2k) or a 2k raise, you’re probably better off taking the leave.

> By being a legal requirement and not a choice, that $29k doesn’t register to the market as using disposable income, so competitive pressure doesn’t inflate prices of everything to compensate.

In competitive markets prices approach the cost of production rather than absorbing all of the disposable income of the customer. If you have uncompetitive markets, that is a separate problem with its own solutions.

And then you have the other problem. The job pays $29k less because it costs the company that much to avoid those costs, i.e. they’re willing to pay that much more to someone in the US to do the same job. That doesn’t mean you’re getting $29k in value. Some of the money is going to compliance and administration rather than you.

And in general money is worth more than stuff, because if you want the stuff you can buy it with money, but if you don’t want that specific stuff then turning it back into money or other stuff at best incurs transaction costs and at worst isn’t even achievable.

The notion that you’re not taxed on the stuff is also an illusion; the rules apply to everyone in the jurisdiction and the government needs however much money from people to provide the services it provides so if you’re not paying it there you’re either paying it somewhere else or getting fewer government services.

> In competitive markets prices approach the cost of production rather than absorbing all of the disposable income of the customer. If you have uncompetitive markets, that is a separate problem with its own solutions.

All markets are a bit uncompetitive — if they were not, if they were perfectly elastic and frictionless cows in a vacuum, then not only would anyone making a profit be undercut by someone willing to make less profit, a cycle which would repeat until profits became zero, but so too would wages be undercut by anyone else willing to provide the labour for less, with the same cycle driving income to subsistence + internet in our present case (or pennies per kloc when LLMs get better).

> All markets are a bit uncompetitive

Oh sure, but there’s a vast difference between “people make $1000 more and landlords take $0.05 on the dollar” and “people make $1000 more and landlords take $0.95 on the dollar”.

Profit margins are also not inherently determined by wages in some other sector. If a bag clip costs $1 and $0.25 of that is profit and $0.75 is cost of labor, the profit margin clearly isn’t zero. If nurses then get a pay raise that came out of reduced overhead rather than higher prices, the unrelated $1 item can profitably be produced for the same price it always was.

In can, indeed, go the other way. Some item is $1.00, $0.75 of that is labor, you eliminate some regulatory overhead which reduces the company’s labor costs (e.g. need fewer HR/lawyers) and now the labor costs fall to $0.60. But this also reduces barriers to entry to the market, so competition increases, the profit component drops to $0.20 and now the item costs $0.80 instead of $1.00.

The way I usually phrase the problem here is that the market strives to push average disposable income to zero. Average here means that there will be people with various degree of spending money surplus (the rich) and those not able to afford even the essentials (the poor). This is a stable(ish) state, even as people move up and down the wealth ladder. However, when suddenly a large chunk of population gets extra disposable income – say a hypothetical UBI experiment (or not so hypothetical universal or near-universal social handouts), or as two-income household model gains popularity in a country, or (indirectly) some innovation creates a new, widely-applicable efficiency – then the market absolutely swoops in and eats all the average surplus.

You mention some regulatory overhead being eliminated, but more often than not, a surplus of disposable income enables passing further regulatory requirements that improve (or at least purport to) safety or quality of products and services, and that were hitherto too costly to implement. Then, most sectors aren’t nearly competitive enough to keep the margins to zero, and some degree of price fixing is a natural thing that happens without any actual collusion, so things get more expensive (per unit) (or don’t get cheaper). Then, like with new regulations, you also get new products and services that had no market yesterday, become popular today, and a de-facto requirement of living tomorrow. Etc.

> Oh sure, but there’s a vast difference between “people make $1000 more and landlords take $0.05 on the dollar” and “people make $1000 more and landlords take $0.95 on the dollar”.

If I parse this correctly, then the latter is definitely the case. Real estate is the prime force that eats all surplus disposable income. Houses and apartments get smaller, get built from worse and worse materials, using inferior techniques, and designed for ever shorter life span, all while getting more and more expensive. Any sudden bump in disposable income across the population is, first and foremost, likely to be eaten by rent.

> However, when suddenly a large chunk of population gets extra disposable income – say a hypothetical UBI experiment (or not so hypothetical universal or near-universal social handouts), or as two-income household model gains popularity in a country, or (indirectly) some innovation creates a new, widely-applicable efficiency – then the market absolutely swoops in and eats all the average surplus.

My argument is that this is not a feature of markets but rather government action.

The rise of two-income households is a great example. Historically only the husband worked for money and the wife would do domestic work like washing clothes etc. Now the washing machine washes the clothes, which takes 15 minutes of human labor instead of four hours, and the labor is then spent working a job that does something else. Meanwhile the family has more money, which allows them to buy those same additional products and service now being provided.

And yet this hasn’t happened. The surplus went somewhere else. You already know where:

> You mention some regulatory overhead being eliminated, but more often than not, a surplus of disposable income enables passing further regulatory requirements that improve (or at least purport to) safety or quality of products and services

It “enables” that to happen, but we as a populace are not actually required to do that. And when we do, the overhead eats the surplus. So maybe we shouldn’t?

> If I parse this correctly, then the latter is definitely the case. Real estate is the prime force that eats all surplus disposable income.

Oh, absolutely. This is why uncompetitive markets are a problem.

Real estate is an unusual case, because the really isn’t anyone with a monopoly on real estate. The supply constraint comes directly from the government through zoning rules. We effectively have a cartel whose board of directors is the zoning board.

In a free market, if wages go up, people who had been living with their parents will want to get their own place, so they would use the extra money they’re making to do that, and the extra money would pay construction companies to build more housing. But if that’s prohibited by law then the extra money only goes to bid up the price of existing housing, people don’t get housing who didn’t have it before because new housing is not created, and the money just goes to landlords.

That is an independent problem that we badly need to solve, because it isn’t just a problem when people make more money. If you get more benefits, the same thing happens. If companies all start providing free daycare, people save the money they’d been using to pay for daycare, they want to use the money to get their own place, rents go up. If prices go down, the same thing happens. Computers get cheaper, you can get a suitable one for $400 instead of $2000, landlords take most of the difference. This needs to be fixed or it eats any surplus that would otherwise go to the middle class. It’s a huge problem, but it’s a solvable problem. Build more housing.

And either way it doesn’t affect whether you should prefer cash or “benefits” as compensation, because when a market with an artificial supply constraint is eating the bulk of any surplus, it would just as well eat the surplus created by benefits too. At which point we’re back to “money is better than arbitrary stuff” because turning money into stuff you want has lower deadweight friction losses than turning stuff you want less into stuff you want more.

> Real estate is an unusual case, because the really isn’t anyone with a monopoly on real estate. The supply constraint comes directly from the government through zoning rules. We effectively have a cartel whose board of directors is the zoning board.

It happens basically everywhere, even when the rules are different. If I understand correctly, the primary limit in the UK is there’s not enough builders, which is not to say the government isn’t in the way as that’s despite it also having constant planning issues with regard to the “green belt”; likewise in modern Germany, my understanding is not enough builders (and again yes the government could be better because bureaucracy is very slow, but they’re not the limiting factor); likewise DDR (not even trying to be a free market) where the government was organising the construction work and trying to do it cheap and fast but there still wasn’t enough.

Of course you’d want to put those terms in the employment contract, not just a verbal promise. Surely you wouldn’t get exactly the same protection as in another country with a completely different legal system, but at least you could get part of it.

And yeah, they could terminate the contract, but they would still be bound by its terms that say how they can do that, with how much notice, for what reasons, and how much they will owe you.

Contract law is strong. If a company deliberately gave the employee lots of rights in an employment contract (in return for less pay), a court would hold the company to that later whilst it was solvent, even if company management later changes it’s approach.

No, you are not buying that in your salary. The cost of living is shared more evenly in most European countries. You may consider it an insurance, and most insurance policies don’t work if there is only one buyer.

You are effectively buying those labour protections with the difference in salary.

There may be some truth to this, but it’s not as stark as some think.

The average cost of a “moderate” house in.. say, Palo Alto is around $3M USD. Those are typically older houses, smaller lots, less desirable neighbourhoods.

Everything is more expensive in such an area. Property tax on that $3M USD house is likely going to be about $20k USD per year, one may as well say an additional $2000/month. That property tax alone is more than most people pay for mortgages in any other place in the US.

I once compared my Ottawa, ON, Canada salary to at typical, comparable one in SV. After looking at the cost of housing, and living, I determined that even though I was making 1/3 the salary? I was taking home more.

Now of course, there is one key difference here. If you don’t rent, and do buy, some of that missing “take home” goes into property which does have value. But if you’re a renter? If your primary cost (housing) isn’t coming back to you in some way?

That SV salary is actually a lot less than you think.

I’d take $100kUSD in Ottawa, over $200kUSD, maybe even $300kUSD in SV, if I wasn’t able to buy. EG, forced to rent. And I’d have more money in my pocket in Ottawa, at end of day.

Oh, and that massive property tax certainly isn’t recoverable. You’re paying some of that whether you rent (because the landlord does), or if you buy.

I reached a similar conclusion back when I was planning what to do if the Brexit referendum went the wrong way (it did).

Even ignoring the labour rights issues (because I didn’t really consider them at the time), rent and other costs were high enough that I was seriously considering a private pilot’s license and a small aircraft for commuting, because that would allow a nice easy fast commute from somewhere that wasn’t priced absurdly. That wouldn’t actually have worked either, but I decided against the USA well before pursuing that to more than a superficial calculation — if I had, then it wouldn’t have taken until Scott Manley’s videos showing me the flight considerations(0) in the area, to learn why this wasn’t going to happen.

(0) “I know, I’ll commute by light aircraft to somewhere in the middle of a city that has a huge international airport and is ‘one of the busiest airspace in the world'”, yeah, no https://johmathe.github.io/flying_bay_tour.html

A big section of this is the petrodollar creating an perversly stong USD.

As that dies off and the USD rebalances to a post American empire equilibrium, housing priced in USD will be far more similar everywhere, exactly the same way it did post British and French empires. (back when 1gbp would buy you 10usd)

I don’t get the reasoning here. Costs in SV are a direct result of the economic powerhouse it is, and the size of the local population. A lot of people cite all sorts of other reasons, but those reasons exist in every other US state to a degree, and yet many of those states do not have high property costs.

It’s all about population density compared with economic might.

If the USD was to crash tomorrow, people in SV would still draw their salaries, housing would still be the same price relative to them. You’re not going to erase costs due to population density and economic drive, because a dollar drops a bit.

Not to mention, the UK has a GDP basically half the US per capita. That has nothing to do with a petro dollar or not. I really see the “petro dollar” thing is a talking point, without the validity to back it up.

the best quick source for the “true” value of a currency is the big mac index

https://www.economist.com/big-mac-index

generally speaking USD is going to lose about 50% of its value as the petrodollar and yen carry trade unwind over the next couple of decades.

So to understand what is actually being earnt and spent in the US in a global context, just divide USD prices by 2, then you can see e.g. the US and UK gdp per capita are basically the same.

Its obviously far more complex than this, but that basic rule of thumb still holds even when you add in all the complexity.

The US is not Silicon Valley. You have a much better take home salary if you want to buy a house elsewhere in the US.

You can also choose to live in California for a few years as a renter if you are young, save money and go live elsewhere with the savings. Ask me how I know you can do that…

Housing in Ottawa is ridiculously expensive. Good luck buying a home for less than $1M and even then you’re looking at a considerable commute.

How one can take a 67% pay cut and have housing still high means you have more in your pocket you’re going to have to explain.

Yeh this person’s argument makes no sense in the context of today’s Ontario, but did about 5+ years ago. Housing price inflation here has made the lower SWE salaries here very uncompetitive.

And it’s not just the house itself, goods and services associated with real estate have blown up with it. Home renovations and maintenance work on your home (if you can even find a contractor) are just stupid. So even if you bought in years ago (like I did), the carrying costs are very high.

That’s why this take came across as unrealistic to me.

Housing has exploded in Canada over the last decade. Even in smaller cities like Ottawa, the prices are more expensive than cities like Chicago.

Then layer on top low salaries, and housing affordability is worse in Canada than many US cities.

You need to compare like for like. If you’re talking about homes in Kanata, then you need to look at homes the same distance in the East Bay where you can buy for under $1M as well.

A $3M home in Palo Alto is comparable to a Ottawa home in the core of the city. And not a townhome, a detached single family home.

If you’re going to compare in this way, wouldn’t ‘most expensive in the metro area’ be San Fransisco compared to ‘most expensive in the metro area’ downtown Ottawa?

Palo Alto is like Kanata, price wise. Ottawa core is like San Fran.

That’s not true.

The higher wages in the US are not related to labour protections. They are related to vastly higher wages in tech because of big corps pushing up those wages to have the best of the best working for them.

Proof is simple: Since a lot of low paying jobs in the US have no labour protections.

Or look at what Tesla does in Texas, with the “unprotected” third party companies that don’t have labour protections. They are vastly worse off than those that work for Tesla ( since the country required minimum protections and Tesla didn’t apply that to contractors)

> Proof is simple: Since a lot of low paying jobs in the US have no labour protections.

That doesn’t follow. The low paying jobs exist because the value to the employer of hiring someone exceeds the low pay. For those jobs, if the employer is required to provide paid vacation etc. then it can push the cost of hiring someone over the cost of offshoring the job or automating it, so the alternative then isn’t high pay vs. low pay, it’s have a job vs. no job.

Also, many of the costs are in proportion to the pay, e.g. the cost of a vacation day is the cost of paying someone else to cover, so the difference will often be a percentage rather than a fixed amount. Then it’s no surprise that skilled professionals get paid more than unskilled labor, but that doesn’t mean the unskilled laborers can’t still be making more than they would be in the alternative where the company had higher costs to hire them.

> Or look at what Tesla does in Texas, with the “unprotected” third party companies that don’t have labour protections. They are vastly worse off than those that work for Tesla ( since the country required minimum protections and Tesla didn’t apply that to contractors)

They have fewer employee benefits, but in return contractors generally get higher hourly wages. One way or another they have to convince the worker to work for them instead of somebody else.

Total comp for experienced software engineers in Silicon Valley exceeded $750k/yr for several years.

Your argument makes no sense.

It was a bubble, but a bubble that has been inflated for a very long time.

Whether software engineers making $750k/year is a bubble has nothing to do with my argument at all. The average annual wages in the US are ~$77,000, compared to ~$55,000 for France or the UK.

You’re totally missing the point. Tesla set their factory and the poorest area in Texas. They wanted worker protections because they were scared to be exploited by a big corporation.

Here’s the reality:

https://fortune.com/2022/11/15/tesla-texas-gigafactory-const…

> ‘I’m going to die in this factory’: Tesla Texas gigafactory construction workers are suing over wage theft and dangerous conditions

But sure…

> They have fewer employee benefits, but in return contractors generally get higher hourly wages. One way or another they have to convince the worker to work for them instead of somebody else.

“generally”

> Other whistleblowers will complain that they were either not paid at all for their work, or were not given proper overtime compensation. Some who sacrificed their time to work over Thanksgiving say that they were never paid the promised double wage, according to the case referral.

Next time. Please come with sources. Because I couldn’t find any credible sources for your claims…

The problem is that this additional salary in turns inflates the housing market or tuition fees, and at the end of the day you’re not earning that much in exchange for the protection you gave up.

And in countries such as Germany you are legally required to be an employee if you only work for one company. The government will sue the company or if not reachable, they will sue the employee.

So deel.com is a usual choice.

Belgian healthcare started like that. First, workers personally kept apart a part of their wages. Then people in 1 factory pooled their money together. Then clusters of factories united into ‘verbonden’, a union-like construct . These where, like a lot of things at the time, grouped by world view:. Christian, socialist, …

After a while, the governement wanted in, joined the verbonden to landsbonden (Country level insurers grouped by world view) and put themselves in the money stream.

The end result is Belgium having a weird construction half way between private health insurance and country-level health insurance.

> ‘verbonden’

Co-op is the word you’re looking for. These co-ops went far beyond just healthcare after all. They owned bakeries, pharmacies, entertainment facilities for the workers, …

There isn’t really a good translation, the concept doesn’t really exist in other countries. They have aspects of unions, co-ops, governemental and political organisations. In the past, they had their own legal status. Today, the EU forced them to become real corporations, and e.g. had them split of the travel aspects from the health insurance aspects.

> we promise

There you go.

Remember folks: a company’s interests are directly opposite to yours. If it makes enough money to not hold their promise, they will.

I don’t want promises from an actor that is structurally infinitely more powerful than I ever will be. This is why not only must this be on contract and enforceable at any time, but individualistic mindset is always against our interests, because it’s easy to promise to one who will be able to defend themselves and plunder another one who can’t.

It’s not my choice, it’s our choice.

I am in Australia. We are somewhere in between, not as strong as Germany or Western EU countries but infinitely better than US. When some of us were laid off by a US tech firm in 2023 they had to give us prior notice for consultation and not cut off our access immediately like they did in US. This allowed us a week to understand our rights and find out the mistakes in their offer. They had to go back and come back with a new better offer as per Australian laws.

In Australia we have codified National Employment Standards which are strictly enforced.
https://www.fairwork.gov.au/employment-conditions/national-e…

The number of US tech businesses that are surprised they need, or think they can ignore the need, to obey employment and data protection laws when working in other jurisdictions is simply bonkers.

In the US, you usually don’t have a work contract. In many states the employer can fire you for any reason except for being a member of a protected class. Or change the terms of working there.

In such states, employees can also leave for any reason, but the asymmetry of the power dynamic means the “at will” laws are generally more beneficial to the employer.

Ireland has an organisation called the Workplace Relations Commission, anyone can log a complaint against their current or former employer without getting the lawyers involved. The case gets reviewed and if warranted a payment can be required. I believe this case was their highest ever award.

It’s nice to have these labour laws, but they only help if you find yourself in the right situation, like this guy, a somewhat senior employee who stands to get a nice payout, and can therefore afford to engage in a legal battle.

But the most vulnerable of us are new grads or people with little experience, and most of the time the abuse from the bosses falls in a gray zone, where it is not clearly illegal, but still very damaging for the future of our careers. And no laws or unions will protect you from that kind of environment.

It’s also worth mentioning, with respect to Germany specifically, that there are a lot of anti-worker customs that would make Americans gasp. For example, the quasi-requirement of having pictures and other personal information on your CV, the fact that racial discrimination is an open secret even though there are laws against it, the requirement of a reference letter from your previous employer, the glass ceiling that you will encounter frequently unless you are part of the right demographic to break into management … I could go on.

As an employee in Germany, I feel abused and helpless. Most of the laws on the books are not written to protect me.
The only thing that really protects people like me is a competitive job market.

> For example, the quasi-requirement of having pictures and other personal information on your CV

Picture was a requirement, but that is slowly becoming less popular. Especially in Tech. Leave it off if you don’t feel like including a Picture. I stopped including a Picture as well some years ago and it has not harmed (or improved) me yet.

Which other personal information is required? I would expect contact information and Name. Of course also your Work History and Education. Which personal information do you have a problem with?

> the requirement of a reference letter from your previous employer,

Yes, they are required to give you a reference letter when you leave the company. Honestly, I have never been asked to provide said letter to my new employer in the 15 Years I have worked in Germany.

Most times I don’t even have one during the hiring process since I am still working there. So, even if asked about a reference letter, I would just reply that I do not have one. Which, again, has not happened to me yet.

>Picture was a requirement, but that is slowly becoming less popular. Especially in Tech.

it’s barely even necessary in this day and age. Just search up John Doe, Job Title, citysville, State and odds are you’ll find some LinkedIn (they probably applied that way anyway). If not, a twitter or open Facebook or more. lot of the newer generations happily give out such private info.

In Germany, every large company is required to have a worker’s committee, elected by the employees. They have the ability to block certain kinds of company actions, and negotiate all kinds of policies with the company. They would probably have your back in a situation like the one described in this article.

>As an employee in Germany, I feel abused and helpless.

It’s worse in Austria where you have at will employment with a notice period and can be laid off without any reason so many companies can subtly force you to accept a new contract or just get laid off.

My German co-workers have the healthiest relationship with work in the company because it seems they feel empowered to set boundaries. I often wonder if it’s a commonality in Germany? It doesn’t seem like perfection, they complain about things too, but it seems healthier to a degree from this vantage.

And it’s amazing how much nonsense they don’t have to deal with just because The business will make the Americans do it so as to avoid a works council hassle 😛 I’d like a works council that makes my management pause before they load me up with extra work on top of my normal tasks.

What’s sad is the people who get frustrated by the German’s not having to deal with the bullshit and instead of thinking “we should have that!” they think “They should NOT have that!”

humans are weird.

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