You are talking about the "Double Irish", which was scotched (sorry) in 2020 by Ireland.

The link under your quoted line in the TFA seems to be talking about Apple (and others) preparing for the end of the Double Irish by finding other tax havens.

"Elite tax advisers help Apple Inc. and other corporate giants skirt impacts of crackdown on 'Double Irish' maneuvers."

So, I don't see what's invalid about the TFA's point, which is about tax avoidance in general

Yup, this article isn't great.

As someone close to pharmaceutical manufacturing, the reason why the manufacturing is done in Ireland is for tax benefits for sales in Europe.

So why not have a US factory for US sales? Because it's much more expensive and complex to have two separate factories making the same drug. It's far easier to just scale the Irish factory to serve all global sales.

Even the same companies with Irish factories have US factories as well. It's not like any tax benefit moved that out of the US as well.

It is also kind of an odd article because his assertion "After the 2017 Tax Cuts and Jobs Act (TCJA), imports from Ireland soared." is not at all borne out by graph that immediately follows.

Switzerland is a whole different matter, but such carelessness doesn't improve trust

Your parents medication costs more than a car payment because developing medication is expensive. Developing medication is expensive partly because it's just innately expensive, but mostly because going through the bureaucracy of getting it approved is really expensive. You want cheaper medicine? Then make that faster and cheaper. But there are tradeoffs.

Not at all. It only explains why a pharmaceutical company has an overseas office.

Your parents medication cost more than a car payment because there's no motivation in the US system to reduce prices for most drugs. Quite the opposite for insurers who provide ACA--they're actually incentivized to increase the cost of care so that the 20% they are allowed to spend on marketing, executive compensation, etc can grow as well.

It’s so ironic. Just a couple weeks ago he was touting how he’s getting drug prices down. Except the tariffs kicked in, and now we’re going to be paying 50% more for those generics. If this were a chess move, we just lost our rooks.

I think it has to do with the fact that you can export tge profit to friendlier jurisdictions afterwards.

For this reason a lot of tech companies have subsidiaries in the Nerherlands. Uber is the first examole that comes to mind. All card charges when you take an Uber in Europe are to Uber N.V - which is a Dutch Entity.

25.8% of what? Tax loopholes operate on calculating that, not lowering the percentage.

Is that still going on? I was just reading about it in the Sarah Wynn-Williams book and it sounded like the EU was cracking down on it and bunch of execs were making backroom deals at Davos in the late 2010s to try to get extensions and sweetheart deals of various kinds.

EDIT: Sigh, yeah looks like the famous Double Irish loophole closed in 2020, but there's another scheme that's come up since 2021: https://en.wikipedia.org/wiki/Double_Irish_arrangement

> It’s by firing people, hiring less, and making less investments in the business all else being equal.

This is farcical. The universal response to higher taxes is to create less revenue? Exactly how does this benefit the CEOs salary? Or improve outcomes for shareholders?

> who will pay out profits as salary to themselves rather than reinvesting the money in the company so as to avoid paying taxes on profits twice

The IRS keeps an eye on this. The business owner does not have unlimited runway and the salary selected must be reasonable. It's also not the only tax vehicle available to the owner to reduce or eliminate the "double taxation" that can occur on profit distributions. There's like half a dozen ways to solve this problem from an ownership perspective.

It should also be noted that the personal income tax rate and the capital gains tax rate are likely to offer very different outcomes for the owner. It's hardly as cut and dry as you project.

> A better solution is to slash corporate taxes and raise income taxes on high earners.

So the corporations engage in practices like buybacks and overfund the business and workers wages end up artificially depressed?

A better solution is to examine the problem and respond with appropriately designed policies that are outcome oriented. These "quick fix" and "slash and burn" policies are _precisely_ how we ended up here. Swinging the pendulum all the way to the other extreme creates the same amount of misery just in a different direction.

Australia has another (strange?) solution: Australian public companies pay tax and issue dividends to shareholders. these dividend payments have attached tax credits ("franking credits") that can be used by the shareholder to reduce their income tax, so those dividend payments are not subject to double taxation (being subject to company tax and again to the individual shareholder's income tax).

E.g. suppose you are a shareholder and receive a dividend of $1000 from some australian public company. If the australian company is large it will be subject to a 30% corporate tax rate. If the company paid company tax on earnings before issuing the dividend, then that dividend comes with a $(1000 / 0.7) * 0.3 = $428.57 tax credit which the shareholder can use to reduce their income tax bill.

That said, in terms of the global landscape of low tax jurisdictions, Australia's corporate tax rate of 30% and highest marginal individual income tax rate of 47% make things less attractive.