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IRS Audits Google’s Offshore Tax Strategies

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Washington, D.C. (October 19, 2011)

By Michael Cohn

The Internal Revenue Service is reportedly auditing Google in an effort to learn more about the search giant’s use of foreign subsidiaries to shift profits in the wake of three acquisitions.

One of the deals involved the company’s 2006 acquisition of YouTube, according to a Bloomberg report. The IRS is reportedly looking into how the company valuated software rights and intellectual property licensed in other countries.

A company spokesman classified the IRS audits as a “routine inquiry.” As a large business taxpayer, the company’s taxes are regularly examined by the IRS.

Google has been known to use sophisticated tax strategies dubbed the “Double Irish” and the “Dutch Sandwich” to shift its foreign income to subsidiaries in countries such as Ireland and the Netherlands (see Google Does the ‘Double Irish’ and the ‘Dutch Sandwich’ to Save on U.S. Taxes).

Transfer pricing and the use of foreign subsidiaries to move multinational corporate profits around the world have come under increasing scrutiny. Companies have stepped up their lobbying efforts in a push for a tax holiday on an estimated $1 trillion in repatriated foreign profits, and the idea has found favor with some lawmakers who have introduced legislation that would bring foreign profits back to the U.S. at a low tax rate (see McCain and Hagan Introduce Repatriation Tax Holiday Bill).

2 Comments

Eliminate the problem. Tax the difference between the rate paid on foreign source income and the US. If a country with a higher rate can be found, allow a credit for the difference for income tax actually paid. Maybe, jobs would flow back to the US instead of playing games with numbers to make the books look better.

Posted by: EnrolledAgent | October 19, 2011 12:20 PM

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Repatriation didn't work the first time, why would anyone think it would work a second time? Yes the money will come back to the U.S. for like 5 minutes but then will be used to purchase treasury stock and maybe some other things that will only affect the Financing side of the Cash Flow statement.

Posted by: jrsalvato@gmail.com | October 19, 2011 11:26 AM

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