I can confirm that the recent article in Forbes magazine to which the Deputy refers has come to the notice of officials both in my Department and in the Office of the Revenue Commissioners. Indeed, both offices were approached by the Irish media in relation to the article and it received some coverage in the national press and on radio.
Inquiries have been carried out by the Revenue Commissioners concerning the matter. As part of this process, I understand that contact has been made by Revenue officials with their counterparts in the US Internal Revenue Service – IRS – under the aegis of the Ireland-US double taxation convention. These contacts are ongoing.
As regards US taxation, I should point out that there is no indication that the scheme in question involves the illegal evasion of US tax. Rather, it appears to be an aggressive tax avoidance scheme aimed at taking advantage of certain provisions in the US tax code to shelter income which would otherwise be liable to US tax. It may well be that ultimately such schemes will be challenged by the US revenue authorities. I can assure the Deputy that should the US revenue authorities require any assistance from the Irish authorities in relation to this matter, full co-operation will be extended by Revenue here.
