The Tax Bill

For over a decade Google's income from outside the United States travelled from Ireland to a Dutch holding company and on to Google Ireland Holdings, an affiliate registered in Ireland and resident for tax in Bermuda, which at the time levied no corporate income tax. Tax lawyers call the route the Double Irish with a Dutch Sandwich. Google Netherlands Holdings BV's filing with the Dutch Chamber of Commerce shows €19,900,000,000 passing through in 2017, on which the Dutch company paid €3,400,000 in tax. The figure for 2016 was €15,900,000,000 and for 2018 it was €21,800,000,000. Ireland had closed the structure to new entrants in 2015 and let existing users keep it through 2020. Google stopped at the end of 2019 and said it would license its intellectual property from the United States.

“Double Irish, Dutch Sandwich, and I'm the one who can't afford lunch.”

The Institute on Taxation and Economic Policy read Amazon's own annual reports and found $5,600,000,000 in U.S. profits for 2017 with $0 in federal income tax, then $11,200,000,000 in U.S. profits for 2018 with a federal rebate of $129,000,000, a rate of about negative 1 percent. ITEP attributes the result to tax credits and to the deduction for executive stock options. In the same period Amazon ran a contest for a second headquarters. It drew 238 proposals from across North America, and on 13 November 2018 the company chose Long Island City in Queens and Arlington, Virginia. New York's package came to $1,525,000,000 from the state and about $2,800,000,000 once city programs are counted, by the Citizens Budget Commission's arithmetic. Amazon cancelled the New York half on 14 February 2019.

“They didn't dodge a loophole. They lobbied one into existence.”

The European Commission decided on 30 August 2016 that Ireland's tax rulings for Apple were illegal state aid. By its calculation Apple Sales International paid an effective rate of 1 percent on its European profits in 2003 and 0.005 percent in 2014. The Commission ordered Ireland to recover up to €13,000,000,000 plus interest for 2003 through 2014. Ireland appealed alongside Apple against collecting its own back taxes. The General Court annulled the decision in 2020. The Court of Justice restored it for good on 10 September 2024, eight years after the order. Apple had placed €14,300,000,000 in escrow in 2018, and €14,244,000,000 reached the Irish Exchequer before the account closed on 16 May 2025.

“It took Europe's top court eight years to collect a bill everyone already knew was owed.”

The New York Times reported in March 2011 that General Electric earned $14,200,000,000 worldwide in 2010, $5,100,000,000 of it from American operations, had no U.S. income tax bill for the year and claimed a tax benefit of $3,200,000,000. The paper counted 975 employees in GE's tax department, led by a former Treasury official. GE disputed the account and said it paid taxes and received no refund. ProPublica and Fortune traced the figure to a $3,250,000,000 current tax benefit in GE's financial statements, which is an accounting entry and a different thing from a check from the IRS, and found that GE did make U.S. income tax payments in 2010 in an amount it declined to disclose.

“They didn't pay their fair share. They billed us for the difference.”

The Paradise Papers, published by the International Consortium of Investigative Journalists on 6 November 2017, showed where the Swoosh lived. A Bermuda subsidiary, Nike International Ltd, held the trademark for markets outside the United States and charged royalties to Nike's European headquarters in Hilversum, under an arrangement approved by Dutch tax authorities. When that approval neared its end in 2014 the trademarks moved to a Dutch partnership, Nike Innovate CV, and Hilversum paid it royalties of $982,000,000 in 2015 and $1,130,000,000 in 2016. Nike's offshore profits grew from $6,600,000,000 in June 2014 to $12,200,000,000 by the end of May 2017, taxed at under 2 percent abroad and untaxed in the United States, by ICIJ's account. A company owned the rights to its own logo, placed them in an entity it created, and paid itself to use them.

“Just don't do it - pay your taxes, that is.”