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Aggressive Tax Planning Practices and Inward-FDI Implications for Ireland of the New US Corporate Tax Regime

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  • Frank Barry

    (Trinity College Dublin)

Abstract

National corporate tax systems interact with each other in complex ways. Interactions with the US tax system are particularly important for Ireland given the significance of the US MNC presence in the Irish economy. The US system changed dramatically with the passage of the Trump administration’s Tax Cuts and Jobs Act. This paper outlines the history of corporate tax policy in the two jurisdictions and how the systems interacted up to the time of the recent changes. It also details the type of aggressive tax planning practices that grew up around the location of intellectual property assets. The likely implications of the new US tax regime for intellectual property location and inward FDI in Ireland are then assessed.

Suggested Citation

  • Frank Barry, 2019. "Aggressive Tax Planning Practices and Inward-FDI Implications for Ireland of the New US Corporate Tax Regime," The Economic and Social Review, Economic and Social Studies, vol. 50(2), pages 325-340.
  • Handle: RePEc:eso:journl:v:50:y:2019:i:2:p:325-340
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    References listed on IDEAS

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    1. Desai, Mihir A. & Foley, C. Fritz & Hines, James Jr., 2006. "The demand for tax haven operations," Journal of Public Economics, Elsevier, vol. 90(3), pages 513-531, February.
    2. Altshuler, Rosanne & Fulghieri, Paolo, 1994. "Incentive Effects of Foreign Tax Credits on Multinational Corporations," National Tax Journal, National Tax Association;National Tax Journal, vol. 47(2), pages 349-361, June.
    3. Marshall Reinsdorf & Matthew J. Slaughter, 2009. "International Trade in Services and Intangibles in the Era of Globalization," NBER Books, National Bureau of Economic Research, Inc, number rein09-1.
    4. John Mutti & Harry Grubert, 2009. "The Effect of Taxes on Royalties and the Migration of Intangible Assets Abroad," NBER Chapters, in: International Trade in Services and Intangibles in the Era of Globalization, pages 111-137, National Bureau of Economic Research, Inc.
    5. Rosanne Altshuler & Harry Grubert, 2005. "The Three Parties in the Race to the Bottom: Host Governments, Home Governments and Multinational Companies," CESifo Working Paper Series 1613, CESifo.
    6. Mr. Nigel A Chalk & Mr. Michael Keen & Ms. Victoria J Perry, 2018. "The Tax Cuts and Jobs Act: An Appraisal," IMF Working Papers 2018/185, International Monetary Fund.
    7. Daragh Clancy, 2019. "US corporate tax rate cuts: Spillovers to the Irish economy," Working Papers 38, European Stability Mechanism.
    8. Altshuler, Rosanne & Fulghieri, Paolo, 1994. "Incentive Effects of Foreign Tax Credits on Multinational Corporations," National Tax Journal, National Tax Association, vol. 47(2), pages 349-61, June.
    9. Griffith, Rachel & Miller, Helen & O'Connell, Martin, 2014. "Ownership of intellectual property and corporate taxation," Journal of Public Economics, Elsevier, vol. 112(C), pages 12-23.
    10. James R. Hines & Eric M. Rice, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," The Quarterly Journal of Economics, President and Fellows of Harvard College, vol. 109(1), pages 149-182.
    11. Frank Barry & Adele Bergin, 2012. "Inward Investment and Irish Exports over the Recession and Beyond," The World Economy, Wiley Blackwell, vol. 35(10), pages 1291-1304, October.
    12. Spengel, Christoph & Heinemann, Friedrich & Olbert, Marcel & Pfeiffer, Olena & Schwab, Thomas & Stutzenberger, Kathrin, 2018. "Analysis of US corporate tax reform proposals and their effects for Europe and Germany. Final report: Update 2018," ZEW Expertises, ZEW - Leibniz Centre for European Economic Research, number 181905.
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    Cited by:

    1. John FitzGerald, 2020. "National Accounts for a Global Economy: The Case of Ireland," NBER Chapters, in: Challenges of Globalization in the Measurement of National Accounts, pages 65-101, National Bureau of Economic Research, Inc.
    2. Barry Frank, 2019. "Ireland and the changing global foreign direct investment landscape," Administration, Sciendo, vol. 67(3), pages 93-110, August.

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