Feargal O'Rourke
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Feargal O'Rourke is an Irish accountant and corporate tax expert, who was the managing partner of PwC in Ireland. He developed the Double Irish arrangement used by U.S. firms such as Apple, Google and
Feargal O'Rourke in 2014
Base erosion and profit shifting is a category of corporate tax avoidance strategies used by multinationals to "shift" profits from higher-tax jurisdictions to lower-tax jurisdictions or no-tax locati
The United States Department of the Treasury decided against signing the 2016 OECD anti–BEPS MLI initiative, stating that the U.S.: "has a low degree of exposure to base erosion and profit shifting". International tax academics showed in 2018 that U.S. multinationals are the largest users of BEPS tools in the world; while U.S. tax academics demonstrated, even as early as 1994 that the U.S. Treasury is a net beneficiary from the use of tax havens and BEPS by U.S. multinationals.
Profitability of U.S. subsidiaries (2015 BEA data)
Former Irish Taoiseach Enda Kenny (l), and PwC Partner Feargal O'Rourke (r) architect of two of the largest BEPS tools in the world, the Double Irish (including Microsoft, Google, Facebook, IBM, Johnson & Johnson and Pfizer, amongst many others), and the Green Jersey (as used by Apple in their Q1 2015 "leprechaun economics" restructuring in Ireland)