Overview
1. How does Ireland tax corporations?
• Definition of residency • Special agreements 2. Explain the tax structure Apple was using in Ireland • Who has the right to collect the tax/penalties assessed by the EU Commission? • On whose side is the U.S. – Apple or EU? • Why doesn’t Ireland want to collect the 14 billion Euros and decided to appeal the EU Ruling? • Why was the head office of the Irish Companies not taxed by Ireland? • How were the Irish branches taxed in Ireland? • What kind of agreement did Apple sign with the Irish government? What did it cover? Was it reasonable? • Why does the head office pay Apple U.S. for R&D? Is the payment reasonable? • How do you think the approach by the EU commission with Apple differ from the approach taken a=with Amazon, McDonalds, and FIAT, in Luxemburg and The Netherlands? • How were sales of Apple products in the EU countries structured – taxable? • Why no Subpart F income • How has the TCJA heightened the tension between the U.S. and the EU community