– putting them outside the US tax net. That led American companies to amass more than $1trillion offshore as of the end of 2017, when president Donald Trump’s tax reform changed the treatment of overseas profits.
Most companies acted well ahead of that deadline, replacing their double Irish arrangements with new structures that have the same benefits, said Ed Kleinbard, a tax law professor at the University of Southern California, Los Angeles. Google’s move was unusual in that it suggested the company had acted later than others, he added.
Under double-Irish arrangements, companies could place IP-like patents and trademarks in separate subsidiaries that were legally based in Ireland, but not treated as domiciled there for tax purposes, as long as they were managed and controlled from abroad. That IP could then eventually be channelled through to tax havens like Bermuda.
The Trump administration’s tax reform, passed two years ago, imposed new taxes on companies’ excess profits from IP held overseas, partly to encourage American businesses to bring IP back to the US.
Who needs tax profit on billions coming through our economy when we could charge nothing and just tax their employees on 60k per year? Oh wait.
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Source: IrishTimes - 🏆 3. / 98 Read more »