If you expect a good explanation on the double irish thing, look elsewhere, this talk spends less than a minute on it and does a poor job. A better title would be "How do we make these greedy capitalists pay more money to our governments (so that they can waste it)"
Also what no one mentions is many of these strategies get disallowed upon audit. Coke got hit pretty bad by it to the tune of billions. The issue is that you cant restructure your business to create a false reality. If 100% of your operations and sales are in the us then you wont have a good chance saying your ip is foreign owned and oh by the way our ip paid to the foreign entity is nearly identical to our taxable income.
It is different if the company has legit foreign operations.
People think these strategies work but they dont. The irs is only recently getting around to finishing audits that involve these creative structures.
It's obvious to see that these strategies do work by looking at the effective corporate tax rate of all the companies mentioned. I've never heard of audits like you are talking about for the top few tech companies (Apple, Google, Amazon, Facebook), do you have a pointer?
One of the points in this presentation was that for intangible goods, it's much easier to pull these schemes off, so it makes complete sense to me that Coke would get hit but tech companies would not.
> The irs is only recently getting around to finishing audits that involve these creative structures.
The IRS has been auditing these structures for years, and they completed many audits a decade ago. If I recall correctly, they issued the Coordinated Issue Paper (which addressed these foreign IP transfers and cost-sharing agreements) in 2007.
