Ireland as a Tax Favored Jurisdiction for U.S. Corporations: Minimizing Income Tax on Multinationals' Intangible Income

IP-Based and Debt-Structured BEPS Tools, Rate Arbitrage, R&D Preferences and Special Incentives, GILTI

This program has been cancelled

A live 110-minute CPE webinar with interactive Q&A


Wednesday, July 10, 2019

1:00pm-2:50pm EDT, 10:00am-11:50am PDT


This webinar will provide corporate tax executives and advisers with a practical guide to the tax planning opportunities of maintaining a tax presence in the Republic of Ireland. The panel will discuss corporate rate differentials, specific incentives for research and intellectual property development available to U.S. corporations, and the rules governing special-purpose entities incorporated in Ireland for tax savings.

Description

A widely held global opinion is that the Republic of Ireland is a tax haven, particularly for U.S. multinationals. With a top corporate tax rate of 12.5% and generous tax incentives for research and development activities and intellectual property income, Ireland is a favored jurisdiction for many U.S. companies in particular.

Because the Republic of Ireland is heavily dependent on corporate tax revenues from foreign companies, particularly those from countries with worldwide income tax regimes like the United States, it adopted a vast series of tax preferences to provide incentives for multinationals to invert their operations in Ireland. In addition to low corporate rates, Ireland allowed a significant number of base erosion and profit shifting (BEPS) tools to eliminate most corporate income taxes on qualifying income.

While the government of Ireland disputes the characterization of its corporate tax system as a tax haven, it agreed to eliminate some of the more notorious profit-shifting schemes. However, there are still several structures, most notably the use of special-purpose vehicles, that serve to avoid tax on certain income. The new GILTI provisions in the 2017 tax reform law will require some U.S. multinationals to restructure some operations, but opportunities still abound for tax reduction. Corporate residency rules in Ireland can be complicated, so tax advisers must be aware of risks as well as opportunities for inversion.

Listen as our expert panel provides a practical guide to income tax minimization opportunities in the Republic of Ireland.

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Outline

  1. Corporate income tax structure in the Republic of Ireland
    1. Lowering of rates
    2. Ireland as a tax haven for U.S. companies and other businesses from countries with worldwide tax regimes
    3. Special rates for manufacturing
  2. Tax preferences and incentives offered to foreign firms with intellectual property and patent activity revenues
  3. BEPS tools specific to Ireland
    1. "Double Irish"
    2. "Single malt"
    3. CAIA structures (capital allowances for intangible assets)
    4. Knowledge development box structures
    5. Debt-based BEPS schemes
  4. Establishing corporate residence in Ireland
  5. Residency rules
  6. Impact of 2017 U.S. tax reform on corporate use of BEPS tools

Benefits

The panel will discuss these and other relevant topics:

  • Republic of Ireland tax incentives for both R&D costs and intellectual property revenues
  • Current and former or phased-out BEPS accounting tools, such as "single malt" and "double Irish" arrangements
  • Using special-purpose vehicles and debt structures to reduce or avoid corporate income tax
  • Profiles of companies that can achieve tax savings by relocating operations and assets to Ireland

Faculty

Spencer, James
James W. Spencer, CPA

Director of International Tax Services
Berkowitz Pollack Brant

Mr. Spencer has more than 25 years of international and local accounting experience, including time with national firms...  |  Read More

Additional faculty
to be announced.