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November 1, 2016

Ireland outlines its appeal of EC’s Apple tax ruling

Ireland’s Department of Finance outlined its key arguments to appeal the European Commission’s (EC’s) ruling that it had breached European Union (EU) state aid rules in its tax deal with Apple.

Arguments for the appeal

In a statement, Irish Finance Minister Michael Noonan outlined several arguments for the appeal.

First, he said, Ireland didn’t provide favorable treatment to Apple. The Chairman of Ireland’s Revenue Commissioners has stated that:

  • There was no departure from the applicable Irish tax law,
  • There was no preference shown in applying the law, and
  • The full tax due was paid in accordance with the law.

(more…)

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Categories: International Business Issues
Tags: Apple, EC, EU, Finance, Ireland, Irish, Tax, Tax law, US,
August 19, 2016

IRS Claims Facebook May Have Undervalued IP Transferred to Ireland

Facebook may have understated the value of intangible property transferred to its Irish holding company by “billions of dollars.” That’s according to a petition the U.S. Justice Department and the IRS filed in the U.S. District Court for the Northern District of California.

The petition was filed to enforce certain summonses served on the social media company in connection with outstanding information requested as part of an IRS audit. It makes the following claims: (more…)

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Categories: International Business Issues
Tags: Facebook, international, Ireland, IRS, Tax,
August 18, 2016

IRS claims Facebook may have undervalued IP transferred to Ireland

By Sheba Dalaney, CPA, Principal
ASL International Group

Facebook may have understated the value of intangible property transferred to its Irish holding company by “billions of dollars.” That’s according to a petition the U.S. Justice Department and the IRS filed in the U.S. District Court for the Northern District of California.

The petition was filed to enforce certain summonses served on the social media company in connection with outstanding information requested as part of an IRS audit. It makes the following claims: (more…)

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Categories: International Business Issues
Tags: Facebook, Intangible Property Transfer, Ireland, IRS, Sheba Dalaney, Technology Company Tax Planning,
August 10, 2016

IRS claims Facebook may have undervalued IP transferred to Ireland

Facebook may have understated the value of intangible property transferred to its Irish holding company by “billions of dollars.” That’s according to a petition the U.S. Justice Department and the IRS filed in the U.S. District Court for the Northern District of California.

The petition was filed to enforce certain summonses served on the social media company in connection with outstanding information requested as part of an IRS audit. It makes the following claims: (more…)

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Categories: International Business Issues
Tags: Facebook, Ireland, IRS,
March 23, 2016

Wisconsin Based Battery Maker Moves to Ireland

Washington responds to Johnson Controls’ inversion to Ireland

Inversions continue in the U.S., with Johnson Controls’ deal to merge with Ireland’s Tyco International being the latest example. The plan prompted one U.S. congressman to say it shows the urgent need for Congress to act against inversions. The chairman of the House Ways and Means Committee, separately, said his panel will work toward having a comprehensive international tax reform package ready in 2017. (more…)

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Categories: International Business Issues
Tags: House of Ways and Means Committee, Inversions, Ireland, Johnson Controls, Tyco International PLC,

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