Wednesday, January 8, 2020
Following up on my previous posts:
Los Angeles Times, Google to End Use of ‘Double Irish’ as Tax Loophole Set to Close:
Google has overhauled its global tax structure and consolidated all of its intellectual property holdings back to the U.S., signaling the winding down of a tax loophole estimated to have saved American companies hundreds of billions of dollars.
The internet search company said on Tuesday the move was designed to simplify its corporate tax arrangements and was in line with OECD efforts to limit international tax avoidance, as well as recent changes to U.S. and Irish laws.
Google’s actions came ahead of the close of the so-called double Irish tax loophole, which has been used by U.S. companies to channel international profits through Ireland and on to tax havens like Bermuda — putting them outside the U.S. tax net. That led American companies to amass more than $1 trillion offshore as of the end of 2017, when President Trump’s tax overhaul changed the treatment of overseas profits.
Ireland bowed to international pressure five years ago and agreed to close the scheme, which was popular with technology and pharmaceutical businesses, but companies that already used it were given until the end of 2020 to end the practice. ...
A lack of disclosure requirements means that little is known about how specific companies have adjusted their tax arrangements, said Chris Sanchirico, a law professor at the University of Pennsylvania. “Based on what we have been able to see in the past, there is no reason to think that planning [by multinationals] hasn’t already evolved several generations beyond the kind of classic double Irish that is now officially coming to an end.”