4 ms·

Taxation – Explaining What a Double Irish Sandwich Is

88 points by sschueller 9y ago

sschueller 9y ago
Youtube version: https://www.youtube.com/watch?v=wuxOKhlLfRU https://www.youtube.com/watch?v=wuxOKhlLfRU
- trymas 9y ago
  Shocking: https://youtu.be/wuxOKhlLfRU?t=13m21s https://youtu.be/wuxOKhlLfRU?t=13m21s https://en.wikipedia.org/wiki/Daphne_Caruana_Galizia https://en.wikipedia.org/wiki/Daphne_Caruana_Galizia
  - expertentipp 9y ago
    This assassination had almost no coverage on the continent. EU institutions and member countries apparently have more important issues than billions of euro vanishing without a trace (time to increase the contributions for those employed; those single, childless, and employed soon will not be paid with money at all).
    - wahern 9y ago
      > This assassination had almost no coverage on the continent. Wow, really? Can I assume, then, that continental Europeans stereotype the Maltese as backward and corrupt? That's the excuse for ignoring such things in pretty much every society.
    - cirrus-clouds 9y ago
      >This assassination had almost no coverage on the continent. There was widespread coverage from quite a few news providers. Some UK ones: Channel 4 News: https://www.channel4.com/news/journalist-killed-in-car-bombing-in-malta https://www.channel4.com/news/journalist-killed-in-car-bombi... BBC News: http://www.bbc.co.uk/news/world-europe-41637730 http://www.bbc.co.uk/news/world-europe-41637730 https://www.youtube.com/watch?v=i9N29zj7d4k https://www.youtube.com/watch?v=i9N29zj7d4k
    - ternaryoperator 9y ago
      This assassination was covered in the US. However, I don't understand the coverage either here or in Europe and am hoping that a local Maltese reader might be able to help out. In all the coverage, she's praised to the skies as a tough investigative journalist who uncompromisingly challenged authorities and followed through on corruption. But then you go to her blog, which was her primary reporting outlet, and it's nothing of the kind. Her last post was literally belittling a politician for his posture [1]. The rest of her posts include gossip and snark ("Opposition leader’s wife says convicted drug dealer’s girlfriend is 'one of my closest and most trusted friends'"). [2] And so on. For locals in Malta, or anyone who actually followed her before she was killed, was she viewed in Malta as a serious investigative reporter? TIA. [1] https://daphnecaruanagalizia.com/2017/10/first-things-first-something-horrendous-posture/ https://daphnecaruanagalizia.com/2017/10/first-things-first-... [2] https://daphnecaruanagalizia.com/2017/10/opposition-leaders-wife-says-convicted-drug-dealers-girlfriend-one-closest-trusted-friends-drug-dealers-girlfriend-says-opposition-leaders-wife-close-friends-like/ https://daphnecaruanagalizia.com/2017/10/opposition-leaders-...
unpopular123 9y ago
If you expect a good explanation on the double irish thing, look elsewhere, this talk spends less than a minute on it and does a poor job. A better title would be "How do we make these greedy capitalists pay more money to our governments (so that they can waste it)"
- anonymous5133 9y ago
  Also what no one mentions is many of these strategies get disallowed upon audit. Coke got hit pretty bad by it to the tune of billions. The issue is that you cant restructure your business to create a false reality. If 100% of your operations and sales are in the us then you wont have a good chance saying your ip is foreign owned and oh by the way our ip paid to the foreign entity is nearly identical to our taxable income. It is different if the company has legit foreign operations. People think these strategies work but they dont. The irs is only recently getting around to finishing audits that involve these creative structures.
  - dontreact 9y ago
    It's obvious to see that these strategies do work by looking at the effective corporate tax rate of all the companies mentioned. I've never heard of audits like you are talking about for the top few tech companies (Apple, Google, Amazon, Facebook), do you have a pointer? One of the points in this presentation was that for intangible goods, it's much easier to pull these schemes off, so it makes complete sense to me that Coke would get hit but tech companies would not.
    - sjg007 9y ago
      I mean you could ask your neighborhood search engine. https://www.bloomberg.com/news/articles/2011-10-13/irs-auditing-how-google-shifted-profits-offshore-to-avoid-taxes https://www.bloomberg.com/news/articles/2011-10-13/irs-audit...
  - gnicholas 9y ago
    > The irs is only recently getting around to finishing audits that involve these creative structures. The IRS has been auditing these structures for years, and they completed many audits a decade ago. If I recall correctly, they issued the Coordinated Issue Paper (which addressed these foreign IP transfers and cost-sharing agreements) in 2007.
deleted 9y ago
[deleted]

88 points by sschueller 9y ago

sschueller 9y ago

Youtube version: https://www.youtube.com/watch?v=wuxOKhlLfRU https://www.youtube.com/watch?v=wuxOKhlLfRU

trymas 9y ago
Shocking: https://youtu.be/wuxOKhlLfRU?t=13m21s https://youtu.be/wuxOKhlLfRU?t=13m21s https://en.wikipedia.org/wiki/Daphne_Caruana_Galizia https://en.wikipedia.org/wiki/Daphne_Caruana_Galizia
- expertentipp 9y ago
  This assassination had almost no coverage on the continent. EU institutions and member countries apparently have more important issues than billions of euro vanishing without a trace (time to increase the contributions for those employed; those single, childless, and employed soon will not be paid with money at all).
  - wahern 9y ago
    > This assassination had almost no coverage on the continent. Wow, really? Can I assume, then, that continental Europeans stereotype the Maltese as backward and corrupt? That's the excuse for ignoring such things in pretty much every society.
  - cirrus-clouds 9y ago
    >This assassination had almost no coverage on the continent. There was widespread coverage from quite a few news providers. Some UK ones: Channel 4 News: https://www.channel4.com/news/journalist-killed-in-car-bombing-in-malta https://www.channel4.com/news/journalist-killed-in-car-bombi... BBC News: http://www.bbc.co.uk/news/world-europe-41637730 http://www.bbc.co.uk/news/world-europe-41637730 https://www.youtube.com/watch?v=i9N29zj7d4k https://www.youtube.com/watch?v=i9N29zj7d4k
  - ternaryoperator 9y ago
    This assassination was covered in the US. However, I don't understand the coverage either here or in Europe and am hoping that a local Maltese reader might be able to help out. In all the coverage, she's praised to the skies as a tough investigative journalist who uncompromisingly challenged authorities and followed through on corruption. But then you go to her blog, which was her primary reporting outlet, and it's nothing of the kind. Her last post was literally belittling a politician for his posture [1]. The rest of her posts include gossip and snark ("Opposition leader’s wife says convicted drug dealer’s girlfriend is 'one of my closest and most trusted friends'"). [2] And so on. For locals in Malta, or anyone who actually followed her before she was killed, was she viewed in Malta as a serious investigative reporter? TIA. [1] https://daphnecaruanagalizia.com/2017/10/first-things-first-something-horrendous-posture/ https://daphnecaruanagalizia.com/2017/10/first-things-first-... [2] https://daphnecaruanagalizia.com/2017/10/opposition-leaders-wife-says-convicted-drug-dealers-girlfriend-one-closest-trusted-friends-drug-dealers-girlfriend-says-opposition-leaders-wife-close-friends-like/ https://daphnecaruanagalizia.com/2017/10/opposition-leaders-...

unpopular123 9y ago

If you expect a good explanation on the double irish thing, look elsewhere, this talk spends less than a minute on it and does a poor job. A better title would be "How do we make these greedy capitalists pay more money to our governments (so that they can waste it)"

anonymous5133 9y ago
Also what no one mentions is many of these strategies get disallowed upon audit. Coke got hit pretty bad by it to the tune of billions. The issue is that you cant restructure your business to create a false reality. If 100% of your operations and sales are in the us then you wont have a good chance saying your ip is foreign owned and oh by the way our ip paid to the foreign entity is nearly identical to our taxable income. It is different if the company has legit foreign operations. People think these strategies work but they dont. The irs is only recently getting around to finishing audits that involve these creative structures.
- dontreact 9y ago
  It's obvious to see that these strategies do work by looking at the effective corporate tax rate of all the companies mentioned. I've never heard of audits like you are talking about for the top few tech companies (Apple, Google, Amazon, Facebook), do you have a pointer? One of the points in this presentation was that for intangible goods, it's much easier to pull these schemes off, so it makes complete sense to me that Coke would get hit but tech companies would not.
  - sjg007 9y ago
    I mean you could ask your neighborhood search engine. https://www.bloomberg.com/news/articles/2011-10-13/irs-auditing-how-google-shifted-profits-offshore-to-avoid-taxes https://www.bloomberg.com/news/articles/2011-10-13/irs-audit...
- gnicholas 9y ago
  > The irs is only recently getting around to finishing audits that involve these creative structures. The IRS has been auditing these structures for years, and they completed many audits a decade ago. If I recall correctly, they issued the Coordinated Issue Paper (which addressed these foreign IP transfers and cost-sharing agreements) in 2007.

deleted 9y ago

[deleted]