BEPS -Double Irish/ Dutch Sandwich Hybrid Entity Mismatches – Part II of II

THE CLASSIC DOUBLE IRISH WITH A DUTCH SANDWICH (“DIDS”) In Part I of this article, I discussed the mechanism by which some very prominent U.S. multinational companies have been able to reduce global income tax on mobile income, such as royalties on sales of software to, at times, almo
Read More

BEPS -Double Irish/ Dutch Sandwich Hybrid Entity Mismatches – Part I of II

On Monday, October 6, 2015 the OECD (of which the US is a member)  delivered its long awaited final BEPS (Base Erosion Profit Shifting)  Action Plans.  BEPS, which actually has 15 action points,  is designed to  set up a fair system of global taxation taking into account the global ta
Read More
*Culhane Meadows is ranked by U.S. News/Best Law Firms in Technology Law, Bankruptcy/Reorganization Law, and Information Technology Law. This website and the communications herein may be considered attorney advertising. Previous results are not a guarantee of future outcome. This website is for informational purposes only and does not constitute legal advice. The information herein is not intended to create an attorney-client or similar relationship. Until you establish such a relationship and receive an engagement letter, you have not hired a Culhane Meadows attorney nor become a client of the firm. Whether you are a new or existing client of the firm, Culhane Meadows must determine that there is no conflict of interest and that it is willing and otherwise able to accept the new engagement before representing you on a new matter. Only if and after Culhane Meadows has informed you it is willing and able to accept your new matter should you send the firm any information or documents that you consider private or confidential. Such information will not be treated as private, confidential or otherwise protected from disclosure until Culhane Meadows has communicated in writing that it is willing and able to accept your new matter and provide you with legal counsel. Whether you need legal services and which lawyer or law firm you select are important decisions that should not be based on this website alone.

Accessibility Toolbar