Daily Tax Update - October 14, 2014: Ireland Finance Minister Proposes to Eliminate "Double Irish" Strategy

Ireland Finance Minister Proposes to Eliminate “Double Irish” Strategy:  Michael Noonan, Ireland’s finance minister, proposed today that, beginning January 1, 2015, all companies registered in Ireland would constitute tax residents of Ireland as well.  He indicated that there would be a transition period for companies currently registered in Ireland until the end of 2020.  He stated that the proposed change was meant to eliminate use of the tax minimization strategy known as the “Double Irish.”  Noonan cited the heavy scrutiny of such strategies by the OECD through the BEPS project as motivation for the proposed change.

The financial statement by Ireland’s Minister of Finance can be found here.

Treasury and IRS Issue Regulations on Discharge of Indebtedness Reporting:  Today, the Treasury Department and the IRS issued proposed regulations under Section 6050P to remove the 36-month non-payment testing period as an identifiable event triggering reporting obligations.  Under the proposed rules, taxpayers would no longer be required to file a Form 1099-C, Cancellation of Debt, at the end of the 36-month nonpayment testing period.