I propose to take Questions Nos. 89 and 90 together.
I am informed by Revenue that the Irish taxes covered by the Ireland/United States double taxation treaty 1997 are income tax, corporation tax and capital gains tax and any identical or substantially similar taxes imposed after the date of signature of the treaty. This is provided for in Article 2 of the treaty, which deals with taxes covered. I am further informed that it has been the view of Revenue, since its introduction in 2010, that the domicile levy could not be regarded as a tax covered by that treaty. I am further informed that Revenue does not maintain a record of the number of cases, to the extent that such exist, of attempted claims to exemption from foreign taxation on the basis that the domicile levy has been paid in Ireland.