Thursday, April 26, 2018

Deep dive into Ireland's balance of payments


Interesting post  on the current state of National Income Accounting from the CFR people out yesterday... 'must read' for us imo.... And the timing is interesting as Tim Cook has a meeting with Trump on the same day... hmmmm....

Maybe Cook was having to explain what is REALLY going on to the Trump people?   Which is not accurately being depicted/illustrated by the current national accounting abstractions?  Kudlow the History major will be well over his head here for sure... maybe not Navarro and Ross....

Maybe it would have been a good idea to go over these issues BEFORE the passage of the Jan. 1 tax law that radically adjusted corporate tax policy.... I don't think those tax changes were well thought out in advance and are leading to some at least short term problems...


A U.S. multinational would transfer (sell) IP assets to one of its Irish subsidiaries, thus allowing it to collect the profits associated with those assets. It would then transfer the profits to the second Irish subsidiary, which despite being incorporated in Ireland was “managed and controlled” from Bermuda (or another tax haven) and owned by the Bermuda subsidiary. Differences in the U.S. and Irish tax codes meant that the U.S. considered this subsidiary an Irish company while the Irish tax code considered it a Bermuda company—effectively leaving the company a tax resident of...nowhere.





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