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Well, if you are an international tax lawyer, obviously moves like the Double Irish show that the base of incorporation matters quite a bit: http://en.wikipe
by temphn 15y ago
Well, if you are an international tax lawyer, obviously moves like the Double Irish show that the base of incorporation matters quite a bit:
http://en.wikipedia.org/wiki/Double_Irish_arrangement
The Double Irish arrangement is a tax avoidance strategy
that U.S. based multinational corporations use to lower
their corporate tax liability. The idea is to use payments
between related entities in a corporate structure to shift
income from a higher-tax country to a lower-tax country.
It relies on the fact that Irish tax law does not include
U.S. transfer pricing rules.[1]
Obviously there are many more things one can do to avoid (not evade) US taxes through various international arbitrage opportunities and offshore tax havens.
And I don't see why any company wouldn't do that. Why would you want more of your money wasted in Iraq and Afghanistan?
- rprasad 15y agoFor starters, there are restrictions on the use of the Double Irish structure that generally limit the benefits to IP-based companies (i.e., technology, media, etc.), which is why most of the companies structured this way are technology companies. Manufacturing companies would derive little if any benefit from the Double Irish structure, though this depends on the circumstances of their businesses. Also, in regards to Iraq and Afghanistan, Ireland does not maintain treaties with either nation, so there is no special low rate that would shield such income. (Sorry for the late reply; I don't read HN every day.)