Americas

Ireland, US multinationals to face new tax landscape in 2018

Jim Stewart, Trinity Business School, Trinity College, Dublin discusses how EU tax authorities’ increasing challenges to the tax strategies of US multinationals, their access to information about MNE activities, US tax reform, and the net effect of ‘correlative adjustments,’ are creating a new tax environment for US MNEs, Ireland, and international taxation in general . . .

Europe

Ireland publishes text of tax provisions phasing out “double Irish” and proposing new MNE tax incentives

The Irish government on October 23 published Finance Bill 2014, which gives effect to the taxation-related measures previously announced in the government’s 2015 budget.  

Included are changes to Ireland’s company residence rules which slowly close the “double Irish” corporate tax loophole. Beginning January 1, 2015, all . . .


Irish tax proposal will not eliminate “double Irish,” say attorneys: Even if Ireland eliminates the Irish incorporated non-resident company, the tax benefits of the “double Irish Dutch sandwich,” can still be achieved by setting up a Irish company managed and controlled in Malta or the UAE instead of a Caribbean nation under Ireland’s existing tax treaties with those nations, write Jeffrey L. Rubinger and Summer Ayers LePree of Bilzin Sumberg Baena Price & Axelrod LLP in an October 23 website post. See, Bilzin Sumberg.

Europe

Irish tax proposal will not eliminate “double Irish,” say attorneys

Even if Ireland eliminates the Irish incorporated non-resident company, as proposed in 2015 Irish budget, the tax benefits of the “double Irish Dutch sandwich,”can still be achieved by setting up a Irish company managed and controlled in Malta or the UAE instead of a Caribbean nation because of provisions in Ireland’s existing tax treaties with those nations, writes Jeffrey L. Rubinger and Summer Ayers LePree of Bilzin Sumberg Baena Price & Axelrod LLP in an October 23 website post. See, Bilzin Sumberg.