If Japan wanted to tax Dropbox for sales to Irish businesses that are transacted in Japan, it can do so. The classic Double Irish with Dutch Sandwich is about a

If Japan wanted to tax Dropbox for sales to Irish businesses that are transacted in Japan, it can do so. The classic Double Irish with Dutch Sandwich is about avoiding taxes on non-US revenue in jurisdictions outside the US. That's an issue between Ireland, Holland, and the rest of the world. In no way is it able to shield a multinational from paying taxes to the IRS on revenue generated in the US. You have a similar dynamic within the US between one state's tax code and another's. I've yet to hear anyone articulate a sound case for "repatriation" (doublespeak alert) of overseas profits to the US that didn't amount to US exceptionalism.