Death Of The 'Double Irish Dutch Sandwich'? Not So Fast

Law360, New York (October 27, 2014, 4:15 PM EDT) -- On Oct. 14, 2014, the Irish minister for finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated nonresident (INR) companies to be treated as tax-resident in Ireland beginning Jan. 1, 2015. The goal is to shut down the use of so-called "Double Irish" and "Double Irish Dutch Sandwich" structures commonly used by U.S. multinationals, such as Google, Microsoft, and Facebook, among others, to significantly reduce their worldwide effective tax rate on royalties derived from the exploitation of intellectual property.

Although the rules are proposed to take effect Jan. 1, 2015, so that any new Irish...

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