Eaton Corporation plc is an American-Irish multinational power management company with 2022 sales of $20.75 billion, founded in the United States with global headquarters in Dublin, Ireland, and a secondary administrative center in Beachwood, Ohio. Eaton has more than 92,000 employees and sells products to customers in more than 175 countries.
Abbott Laboratories is an American multinational medical devices and health care company with headquarters in Abbott Park, Illinois, United States. The company was founded by Chicago physician Wallace Calvin Abbott in 1888 to formulate known drugs; today, it sells medical devices, diagnostics, branded generic medicines and nutritional products. It split off its research-based pharmaceuticals business into AbbVie in 2013.
Medtronic plc is an American medical device company. The company's operational and executive headquarters are in Minneapolis, Minnesota, and its legal headquarters are in Ireland due to its acquisition of Irish-based Covidien in 2015. While it primarily operates in the United States, it operates in more than 150 countries and employs over 90,000 people. It develops and manufactures healthcare technologies and therapies.
Boston Scientific Corporation ("BSC"), incorporated in Delaware, is a biomedical/biotechnology engineering firm and multinational manufacturer of medical devices used in interventional medical specialties, including interventional radiology, interventional cardiology, peripheral interventions, neuromodulation, neurovascular intervention, electrophysiology, cardiac surgery, vascular surgery, endoscopy, oncology, urology and gynecology. Boston Scientific is widely known for the development of the Taxus Stent, a drug-eluting stent which is used to open clogged arteries. With the full acquisition of Cameron Health in June 2012, the company also became notable for offering a minimally invasive implantable cardioverter-defibrillator (ICD) which they call the EMBLEM subcutaneous implantable defibrillator (S-ICD).
Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force, and created 57% of Irish OECD non-farm value-add. As of 2017, 25 of the top 50 Irish firms were U.S.–controlled businesses, representing 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. § Corporate tax inversions in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system.
Perrigo Company plc is an American Irish–registered manufacturer of private label over-the-counter pharmaceuticals, and while 70% of Perrigo's net sales are from the U.S. healthcare system, Perrigo is legally headquartered in Ireland for tax purposes, which accounts for 0.60% of net sales. In 2013, Perrigo completed the sixth-largest US corporate tax inversion in history when it reregistered its tax status to Ireland to avoid U.S. corporate taxes. Perrigo maintains its corporate headquarters in Grand Rapids, Michigan, within Michigan State University's Grand Rapids Innovation Park.
Zimmer Biomet Holdings, Inc. is a publicly traded medical device company. It was founded in 1927 to produce aluminum splints. The firm is headquartered in Warsaw, Indiana, where it is part of the medical devices business cluster.
Sierra Wireless is a Canadian multinational wireless communications equipment designer, manufacturer and services provider headquartered in Richmond, British Columbia, Canada. It also maintains offices and operations in the United States, Korea, Japan, Taiwan, India, France, Australia and New Zealand.
Actavis Generics is a global pharmaceutical company focused on acquiring, developing, manufacturing and marketing branded pharmaceuticals, generic and over-the-counter medicines, and biologic products. Actavis has a commercial presence across approximately 100 countries. The company has global headquarters in Dublin, Ireland and administrative headquarters in Parsippany-Troy Hills, New Jersey, United States.
Mallinckrodt Pharmaceuticals is an American-Irish domiciled manufacturer of specialty pharmaceuticals, generic drugs and imaging agents. In 2017 it generated 90% of its sales from the U.S. healthcare system. While Mallinckrodt is headquartered in Ireland for tax purposes, its operational headquarters are in the U.S. Mallinckrodt's 2013 tax inversion to Ireland drew controversy when it was shown Acthar was Medicaid's most expensive drug.
Valence Technology, Inc. was a company that developed and manufactured lithium iron phosphate cathode material as well as lithium ion battery modules and packs. The modules come in 12 V, 18 V, 24 V, and 36 V configurations. Valence's products are used in electric vehicle and plug-in hybrid electric vehicles (PHEVs) such as cars, scooters, motorbikes, and commercial vehicles such as buses, delivery vans and trucks. Valence batteries are also used in wheelchairs, medical carts, robotics, marine, rail, as well as stationary applications such as remote power, uninterruptible power supply (UPS), energy storage systems, frequency regulation and switching gear.
A tax inversion or corporate tax inversion is a form of tax avoidance where a corporation restructures so that the current parent is replaced by a foreign parent, and the original parent company becomes a subsidiary of the foreign parent, thus moving its tax residence to the foreign country. Executives and operational headquarters can stay in the original country. The US definition requires that the original shareholders remain a majority control of the post-inverted company.
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mostly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history and by 2010 was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement.
Established in 2001, Vidacare Corporation was the developer of intraosseous medical devices. Its devices were used in vascular access, emergency and disaster medicine, oncology, and spinal surgery. Privately held, the company was based in San Antonio, Texas, and its products were marketed in over 50 countries worldwide.
Horizon Therapeutics Public Ltd Co is a biopharmaceutical company focused on researching, developing, and commercializing medicines that address critical needs for people impacted by rare and rheumatic diseases. Horizon primarily markets products in the United States, which represented 97% of Horizon's 2019 worldwide sales.
CEB, now a part of Gartner, was a company providing best practice research, benchmarks, and decision support tools to business leaders in HR, Finance, IT, Marketing, Sales, Customer Service, Strategy, R&D, Procurement, Legal, and Compliance functions globally. It was one of the first firms to offer a subscription pricing model for insights and advice, challenging the prevailing consulting delivery model and paving the way for subscription-as-a-service ("SaaS") pricing models now favored by software companies. Gartner announced its acquisition of CEB in January 2017, completed the acquisition in April 2017, and integrated the company in July 2018.
Allergan plc is an American, Irish-domiciled pharmaceutical company that acquires, develops, manufactures and markets brand name drugs and medical devices in the areas of medical aesthetics, eye care, central nervous system, and gastroenterology. The company is the maker of Botox.
Dutch Sandwich is a base erosion and profit shifting (BEPS) corporate tax tool, used mostly by U.S. multinationals to avoid incurring European Union withholding taxes on untaxed profits as they were being moved to non-EU tax havens. These untaxed profits could have originated from within the EU, or from outside the EU, but in most cases were routed to major EU corporate-focused tax havens, such as Ireland and Luxembourg, by the use of other BEPS tools. The Dutch Sandwich was often used with Irish BEPS tools such as the Double Irish, the Single Malt and the Capital Allowances for Intangible Assets ("CAIA") tools. In 2010, Ireland changed its tax-code to enable Irish BEPS tools to avoid such withholding taxes without needing a Dutch Sandwich.
Steris plc is an Irish-domiciled medical equipment company specializing in sterilization and surgical products for the US healthcare system. Steris is operationally headquartered in Mentor, Ohio, but has been legally registered since 2018 in Dublin, Ireland for tax purposes; it was previously registered in the United Kingdom from 2014 to 2018. Steris is quoted on the NYSE, and is a constituent of the S&P 500 Index.
Repatriation tax avoidance is the legal use of a tax regime within a country in order to repatriate income earned by foreign subsidiaries to a parent corporation while avoiding taxes ordinarily owed to the parent's country on the repatriation of foreign income. Prior to the passage of the Tax Cuts and Jobs Act of 2017, multinational firms based in the United States owed the U.S. government taxes on worldwide income. Companies avoided taxes on the repatriation of income earned abroad through a variety of strategies involving the use of mergers and acquisitions. Three main types of strategies emerged and were given names—the "Killer B", "Deadly D", and "Outbound F"—each of which took advantage of a different area of the Internal Revenue Code to conduct tax-exempt corporate reorganizations.
