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Tax Havens & Tax Planning

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Read the case, Double Irish and a Dutch Sandwich.

1. Why do tax rates and tax treatment of corporate income vary so dramatically among countries?
2. Explain the use of the Double Irish and the Dutch Sandwich by Google.
3. How important is the advance pricing agreement that Google negotiated with the Internal Revenue Service to the success of its tax-minimization strategy?
4. Explain how Microsoft uses its Irish subsidiary to cut its U.S. taxes. How does it get around U.S. regulations regarding passive income?
5. What is the impact of Microsoft's Irish subsidiary on the Irish economy?

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Solution Summary

The response provides you a structured explanation of locating subsidiaries in low tax countries to reduce tax burden. It also gives you the relevant references.

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1. You should introduce your subject in this manner:
1. A thesis statement
As there is wide variations in corporate income tax among countries, companies uses subsidiaries in low tax countries and tax havens to reduce their tax bill.
2. Purpose of paper:
The purpose of the paper is to show how corporate tax rates vary widely among countries, and describe some of the strategies used by multinational corporations to use these differences to reduce their tax burden.
3. Overview of paper:
The reasons why tax rates and tax treatment of corporate income vary so much among countries is discussed. Next, the use of Double Irish and Dutch Sandwich technique by Google is discussed next. After this the importance of 2006 advance pricing agreement between Google and Internal Revenue Service is discussed. Next, the strategy of Microsoft in using its Irish subsidiary to reduce US taxes, and how it gets around the passive income clause in the IRS clause. Finally, the impact of Microsoft's Irish subsidiary on Irish economy is evaluated.

You can say that the body is :
Main Issue 1
Tax rates and tax treatment of corporate incomes vary dramatically across countries because politicians do not consider the benefits of comparative advantage(1). They do not consider the productivity generated by specialization of labor, or harmful effects of trade barriers. They are interested in stimulating the local economy and the politicians are focused on job creation and tax revenues. This leads to large variations in corporate income tax(2).

Main Issue 2
Google's Double Irish and Dutch Sandwich is a strategy to reduce taxes by $3.2 billion over three years. In 2006 Google entered into an advance pricing agreement with the Us ...

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  • BSc , University of Calcutta
  • MBA, Eastern Institute for Integrated Learning in Management
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