摘要：National corporate tax systems interact with each other in complex ways. Interactions with
the US tax system are particularly important for Ireland given the significance of the US MNC presence
in the Irish economy. The US system changed dramatically with the passage of the Trump
administration’s Tax Cuts and Jobs Act in late 2017. This paper outlines the history of corporate tax
policy in the two jurisdictions and how the systems interacted up to the time of the recent changes. It
also details the type of aggressive tax planning practices that grew up around the location of intellectual
property assets. The likely implications of the new US tax regime for intellectual property location and
inward FDI in Ireland are then assessed.
其他摘要：National corporate tax systems interact with each other in complex ways. Interactions with the US tax system are particularly important for Ireland given the significance of the US MNC presence in the Irish economy. The US system changed dramatically with the passage of the Trump administration’s Tax Cuts and Jobs Act. This paper outlines the history of corporate tax policy in the two jurisdictions and how the systems interacted up to the time of the recent changes. It also details the type of aggressive tax planning practices that grew up around the location of intellectual property assets. The likely implications of the new US tax regime for intellectual property location and inward FDI in Ireland are then assessed.
关键词：taxation;foreign direct investment;FDI;Ireland;United States
