Search results
Results from the WOW.Com Content Network
In October 2014, as the EU forced the Irish State to close the Double Irish BEPS tool, [37] the influential U.S. National Tax Journal published an article by Jeffrey L Rubinger and Summer Lepree, showing that Irish based subsidiaries of U.S. corporations could replace the Double Irish arrangement with a new structure (now known as Single Malt ...
Double Irish arrangements have allowed multinational companies to avoid taxes owed to countries in which foreign subsidiaries of a U.S.-based multinational corporation are incorporated. Repatriation tax avoidance strategies, however, have allowed U.S.-domiciled companies to avoid owing taxes to the United States.
The Double Irish was the largest BEPS tool in history which by 2015, was shielding over US$100 billion in mostly US corporate profits from US taxation. When the EU Commission fined Apple €13 billion for using an illegal hybrid-Double Irish structure, their report noted that Apple had been using the structure from at least as far back as 1991 ...
The U.S. administration condemned Apple's Irish tax structures in the 2013 Levin–McCain PSI, [59] [60] [61] however, it came to Apple's defense when the EU Commission levied a €13 billion fine on Apple for Irish tax avoidance from 2004 to 2014, the largest corporate tax fine in history, arguing that Apple paying the full 12.5% Irish ...
The Irish tax code considers IRL2 a Bermuda company (used the "managed and controlled" test), but the US tax code considers IRL2 an Irish company (uses the registration test). Neither taxes it. Apple's subsidiary, ASI, behaved like it was IRL2, it was "managed and controlled" via ASI Board meetings in Bermuda, so Irish Revenue did not tax it.
Tax evasion, on the other hand, is the general term for efforts by individuals, corporations, trusts and other entities to evade taxes by illegal means. Both tax evasion and some forms of tax avoidance can be viewed as forms of tax noncompliance, as they describe a range of activities that are unfavourable to a state's tax system. [11]
An American woman who previously posed as heiress to a fortune faces extradition to Northern Ireland to face charges in connection with alleged schemes in which she is accused of duping investors ...
The Double Irish uses an Irish company (IRL2) that is legally incorporated in Ireland, and thus the US-tax code regards it as foreign, but is "managed and controlled" from, say, Bermuda (and thus the Irish tax code also regards it as foreign). The Dutch Sandwich, with the Dutch company as the "dutch slice" in the "sandwich", is used to move ...