well the need for this has mostly gone away due to the 2017 TCJA. The short version is you can't do this because as a US (assuming?) individual you are subject

well the need for this has mostly gone away due to the 2017 TCJA. The short version is you can't do this because as a US (assuming?) individual you are subject to worldwide taxation (unlike the rest of the world (well except Eritrea)). But the wikipedia article on the double Irish is actually pretty interesting if you are interested in such things and lays out the steps: 1) A U.S. corporate (CORP) develops new software in the U.S. costing $1 million to build; 2) CORP sells it to its wholly owned Bermuda company (BER1) for $1 million (at cost, ideally); 3) BER1 revalues it to $1 billion (as an intangible asset under GAAP), and books gain in Bermuda (tax-free); 4) An Irish subsidiary, IRL1, purchases this intangible asset from BER1, for $1 billion; 5) Under the CAIA rules, IRL1 can write-off the $1 billion paid for this group intangible asset against Irish tax; 6) Additionally, BER1 gives IRL1 a $1 billion 10-year inter-group loan to buy the intangible asset, at an interest rate of circa 7%; 7) Over the next 10 years IRL1 claims tax relief on both the $1 billion purchase (under CAIA), and the inter-group loan interest; 8) During the 10 years, IRL1 charges out this asset to end-customers globally (as per step v. in the Double Irish), accumulating profits; 9) During the 10 years, CORP in line with its product cycle, has created new software and repeated step i. to iii. above; 10) At the end of the 10 years, IRL1 has shielded $1.7 billion of Irish profits against Irish tax; 11) At the end of the 10 years, BER1, who received the $1 billion purchase price, and $0.7 billion in loan interest, has paid no tax; 12) At the end of the 10 years, IRL1, repeats steps iv. to ix. above, and buys a new intangible asset from BER1 for $1 billion. https://en.wikipedia.org/wiki/Double_Irish_arrangement https://en.wikipedia.org/wiki/Double_Irish_arrangement