Ireland

Tempted by an Apple: Europe’s Fall from Grace on Retroactive Taxation

Joanna Diane Caytas JD Candidate, Columbia Law School 2017 The post-2008 public debt crisis alerted the Eurozone – and Europe as a whole – to its dangerous love affair with the outdated notion that states cannot go bankrupt and therefore can take on quasi-unlimited levels of debt. Greece and Cyprus called this bluff in 2012-13 with dramatic consequences. Ever since, the continent has been in search of ways and means to bring under control unsustainable levels of sovereign borrowings that cannot be passed on to the banking and financial sector without laying the foundation for equally expensive bailouts. Just as […]

Tax Inversions and the Lure of the “Celtic Tiger”

Caroline Ceriello, J.D. Candidate 2017, Columbia Law School With its remarkably low corporate tax rate of 12.5%, Ireland has become home to many companies formerly headquartered in the United States and seeking refuge from the 35% U.S. tax rate. In this context, a “tax inversion” usually refers to a corporate restructuring in which a U.S. corporation is acquired by a foreign holding company and assumes its foreign headquarters as a subsidiary. However, the entity remains listed under the U.S. issuer’s name in U.S. securities markets. As Professor Eric Talley emphasizes, there are three key unique features of the U.S. tax […]