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Feargal O'Rourke
Feargal “Sake” O'Rourke (born 3 August 1964) is an Irish accountant and corporate tax expert, who is the managing partner of PwC in Ireland. He is considered the architect of the ''Double Irish'' tax scheme used by U.S. firms such as Apple, Google and Facebook in Ireland, and a leader in the development of corporate tax planning tools, and tax legislation, for U.S. multinationals in Ireland. Personal O'Rourke comes from an established Fianna Fáil political dynasty. He is the son of former Irish Minister Mary O'Rourke, nephew of former Irish Tánaiste Brian Lenihan Snr, and cousin of former Irish Finance Minister Brian Lenihan Jnr, and former Irish Minister of State Conor Lenihan. He chaired the college branch of Fianna Fáil at UCD and joined the national executive on graduation. Double Irish O'Rourke was once labeled the "great architect" of the ''Double Irish'' base erosion and profit shifting ("BEPS") tool, as used by U.S. multinationals in Ireland such as Google, a ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Taoiseach
The Taoiseach is the head of government, or prime minister, of Republic of Ireland, Ireland. The office is appointed by the president of Ireland upon the nomination of Dáil Éireann (the lower house of the Oireachtas, Ireland's national legislature) and the office-holder must retain the support of a majority in the Dáil to remain in office. The Irish language, Irish word ''Wiktionary:taoiseach, taoiseach'' means "chief" or "leader", and was adopted in the 1937 Constitution of Ireland as the title of the "head of the Government or Prime Minister". It is the official title of the head of government in both English and Irish, and is not used for the prime ministers of other countries, who are instead referred to in Irish by the generic term ''príomh-aire''. The phrase ''an Taoiseach'' is sometimes used in an otherwise English-language context, and means the same as "the Taoiseach". The current Taoiseach is Leo Varadkar, Leo Varadkar TD, leader of Fine Gael, who again took offic ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Double Irish Arrangement
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mostly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history and by 2010 was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement. Despite US knowledge of the Double Irish for a decade, it was the European Commission that in October 2014 forced Ireland to close the scheme, starting in January 2015. However, users of existing schemes, such as Apple, Google, Facebook and Pfizer, were given until January 2020 to close them. At the announcement of the closure it was known that multin ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Loopholes
A loophole is an ambiguity or inadequacy in a system, such as a law or security, which can be used to circumvent or otherwise avoid the purpose, implied or explicitly stated, of the system. Originally, the word meant an arrowslit, a narrow vertical window in a wall through which an archer (or, later, gunman) could shoot. Loopholes were commonly used in U.S. forts built during the 1800s. Located in the sally port, a loophole was considered a last ditch defense, where guards could close off the inner and outer doors trapping enemy soldiers and using small arms fire through the slits. Loopholes are distinct from lacunae, although the two terms are often used interchangeably. In a loophole, a law addressing a certain issue exists, but can be legally circumvented due to a technical defect in the law, such as a situation where the details are under-specified. A lacuna, on the other hand, is a situation in which no law exists in the first place to address that particular issue. Use a ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Time (magazine)
''Time'' (stylized in all caps) is an American news magazine based in New York City. For nearly a century, it was published Weekly newspaper, weekly, but starting in March 2020 it transitioned to every other week. It was first published in New York City on March 3, 1923, and for many years it was run by its influential co-founder, Henry Luce. A European edition (''Time Europe'', formerly known as ''Time Atlantic'') is published in London and also covers the Middle East, Africa, and, since 2003, Latin America. An Asian edition (''Time Asia'') is based in Hong Kong. The South Pacific edition, which covers Australia, New Zealand, and the Pacific Islands, is based in Sydney. Since 2018, ''Time'' has been published by Time USA, LLC, owned by Marc Benioff, who acquired it from Meredith Corporation. History ''Time'' has been based in New York City since its first issue published on March 3, 1923, by Briton Hadden and Henry Luce. It was the first weekly news magazine in the United St ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
EU Illegal State Aid Case Against Apple In Ireland
On 29 August 2016, after a two-year investigation, Margrethe Vestager of the European Commission announced: "Ireland granted illegal tax benefits to Apple". The Commission ordered Apple to pay €13 billion, plus interest, in unpaid Irish taxes from 2004–14 to the Irish state. It was the largest corporate tax "fine" (in fact a recovery order, technically not a fine) in history. On 7 September 2016, the Irish State secured a majority in Dáil Éireann to reject payment of the back-taxes, which including penalties could reach €20 billion, or 10% of 2014 Irish GDP. In November 2016, the Irish government formally appealed the ruling, claiming there was no violation of Irish tax law, and that the commission's action was "an intrusion into Irish sovereignty", as national tax policy is excluded from EU treaties. In November 2016, Apple CEO Tim Cook, announced Apple would appeal, and in September 2018, Apple lodged €13 billion to an escrow account, pending appeal. In Ju ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Double Irish
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mostly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history and by 2010 was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement. Despite US knowledge of the Double Irish for a decade, it was the European Commission that in October 2014 forced Ireland to close the scheme, starting in January 2015. However, users of existing schemes, such as Apple, Google, Facebook and Pfizer, were given until January 2020 to close them. At the announcement of the closure it was known that multin ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Dutch Sandwich
Dutch Sandwich is a base erosion and profit shifting (BEPS) corporate tax tool, used mostly by U.S. multinationals to avoid incurring EU withholding taxes on untaxed profits as they were being moved to non-EU tax havens (such as the Bermuda black hole). These untaxed profits could have originated from within the EU, or from outside the EU, but in most cases were routed to major EU corporate-focused tax havens, such as Ireland and Luxembourg, by the use of other BEPS tools. The Dutch Sandwich was often used with Irish BEPS tools such as the Double Irish, the Single Malt and the Capital Allowances for Intangible Assets ("CAIA") tools. In 2010, Ireland changed its tax-code to enable Irish BEPS tools to avoid such withholding taxes without needing a Dutch Sandwich. Explanation The structure relies on the tax loophole that most EU countries will allow royalty payments be made to other EU countries without incurring withholding taxes. However, the Dutch tax code allows royalty p ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Richard Brooks (journalist)
Richard Brooks (born 18 August 1965) is a British investigative journalist and former tax inspector. He writes principally for ''Private Eye'', is the author of books on accountancy and tax avoidance, and was a 16-year senior corporate tax inspector for HMRC. He is the joint winner of two Paul Foot Awards, an annual award for investigative or campaigning journalism. Career Brooks worked as a HM Revenue and Customs tax inspector for 16 years up until 2005 specialising in international and corporate taxation. Since 2005, he has been a regular contributor to Private Eye. In 2008 Brooks was joint-winner of the Paul Foot Award for his investigation into the privatisation of the CDC Group. He is the author of ''The Great Tax Robbery: How Britain Became a Tax Haven for Fat Cats and Big Business'' (2013) and the co-author (with David Craig) of ''Plundering the Public Sector: How New Labour are letting consultants run off with £70 billion of our money'' (2006). With Andrew Bousfield, ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
The New York Times
''The New York Times'' (''the Times'', ''NYT'', or the Gray Lady) is a daily newspaper based in New York City with a worldwide readership reported in 2020 to comprise a declining 840,000 paid print subscribers, and a growing 6 million paid digital subscribers. It also is a producer of popular podcasts such as '' The Daily''. Founded in 1851 by Henry Jarvis Raymond and George Jones, it was initially published by Raymond, Jones & Company. The ''Times'' has won 132 Pulitzer Prizes, the most of any newspaper, and has long been regarded as a national " newspaper of record". For print it is ranked 18th in the world by circulation and 3rd in the U.S. The paper is owned by the New York Times Company, which is publicly traded. It has been governed by the Sulzberger family since 1896, through a dual-class share structure after its shares became publicly traded. A. G. Sulzberger, the paper's publisher and the company's chairman, is the fifth generation of the family to head the pa ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Financial Times
The ''Financial Times'' (''FT'') is a British daily newspaper printed in broadsheet and published digitally that focuses on business and economic current affairs. Based in London, England, the paper is owned by a Japanese holding company, Nikkei, with core editorial offices across Britain, the United States and continental Europe. In July 2015, Pearson sold the publication to Nikkei for £844 million (US$1.32 billion) after owning it since 1957. In 2019, it reported one million paying subscriptions, three-quarters of which were digital subscriptions. The newspaper has a prominent focus on financial journalism and economic analysis over generalist reporting, drawing both criticism and acclaim. The daily sponsors an annual book award and publishes a " Person of the Year" feature. The paper was founded in January 1888 as the ''London Financial Guide'' before rebranding a month later as the ''Financial Times''. It was first circulated around metropolitan London by James Sherid ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Base Erosion And Profit Shifting
Base erosion and profit shifting (BEPS) refers to corporate tax planning strategies used by multinationals to "shift" profits from higher-tax jurisdictions to lower-tax jurisdictions or no-tax locations where there is little or no economic activity, thus "eroding" the "tax-base" of the higher-tax jurisdictions using deductible payments such as interest or royalties. For the government, the tax base is a company's income or profit. Tax is levied as a percentage on this income/profit. When that income / profit is transferred to another country or tax haven, the tax base is eroded and the company does not pay taxes to the country that is generating the income. As a result, tax revenues are reduced and the government is detained. The Organization for Economic Co-operation and Development (OECD) define BEPS strategies as "exploiting gaps and mismatches in tax rules". While some of the tactics are illegal, the majority are not. Corporate tax havens offer BEPS tools to "shift" pr ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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