The Double Irish Sandwich: Reforming Overseas Tax Havens

Stephen C. Loomis (J.D. 2012, St. Mary's), Recent Development, The Double Irish Sandwich: Reforming Overseas Tax Havens, 43 St. Mary's L.J. 825 (2012):

This Recent Development will analyze the current international taxation regime along with the Double Irish arrangement and then offer possible solutions to close the loopholes. Part II will introduce and explain some basic international taxation rules, as a foundation for the analysis. The mechanics of the Double Irish will be examined in Part III. Part IV then investigates the congressional intent behind the Internal Revenue Code provisions that allow for the Double Irish, and looks at some of the consequences of allowing the Double Irish scheme to continue existing. Possible solutions to close the loopholes and harmonize the taxation of domestic and international corporations will be discussed in Part V, and Part VI will provide some concluding thoughts.