Google has overhauled its global tax structure and consolidated all of its intellectual property holdings back to the U.S.
, signaling the winding down of a tax loophole estimated to have saved American companies hundreds of billions of dollars.
Ireland bowed to international pressure five years ago and agreed to close the scheme, which was popular with technology and pharmaceutical businesses, but companies that already used it were given until the end of 2020 to end the practice.well ahead of that deadline, replacing their double Irish arrangements with new structures that have the same benefits, said Ed Kleinbard, a tax law professor at USC.
Under double Irish arrangements, companies could place IP like patents and trademarks in separate subsidiaries that were legally based in Ireland, but not treated as domiciled there for tax purposes, as long as they were managed and controlled from abroad. That IP could then eventually be channeled through to tax havens like Bermuda.Google said by moving its IP from Bermuda to the U.S. it was reacting to changes in U.S.
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