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An Irish Section 110 special purpose vehicle (SPV) or section 110 company is an Irish tax resident company, which qualifies under Section 110 of the Irish Taxes Consolidation Act 1997 (TCA) for a special tax regime that enables the SPV to attain "tax neutrality": i.e. the SPV pays no Irish taxes, VAT, or duties.
Central Bank of Ireland ("CBI") regulates QIAIFs. When Irish public tax scandals concerning the Section 110 SPV, also regulated by the CBI, emerged in 2016–2017, the CBI upgraded the little-used LQIAIF, [1] to give the same benefits as Section 110 SPVs, but with full confidentiality and tax secrecy.
Structures such as the Section 110 SPV are being used to create more advanced artificial loan structures, which are harder to understand and prevent, for BEPS-type activities (including money laundering/regulatory avoidance purposes). There has been a material uplift in Section 110 SPVs by sanctioned Russian financial institutions.
In February 2018, the Central Bank of Ireland, which regulates Section 110 SPVs, upgraded the little used tax-free L-QIAIF regime, which has stronger privacy from public scrutiny. [133] [178] In June 2018, U.S. distressed debt funds transferred €55 billion of Irish assets (or 25% of Irish GNI*), out of Section 110 SPVs and into L–QIAIFs ...
From January 2008 to June 2009, if you bought shares in companies when Eugene I. Davis joined the board, and sold them when he left, you would have a -61.6 percent return on your investment, compared to a -39.2 percent return from the S&P 500.
The SPV is generally a limited liability company issued in either an offshore location (e.g. the Cayman Islands SPV) or an onshore location (e.g. Irish Section 110 SPV). [4] [5] The key considerations in deciding what 3rd party entities are used to "own" the orphaned SPV equity are driven by:
The Irish Section 110 SPV uses complex securitisation loan structuring (including "orphaning" which adds confidentiality), to enable the profit shifting. This tool is so powerful, it inadvertently enabled US distressed debt funds avoid billions in Irish taxes on circa €80 billion of Irish investments they made in 2012-2016 (see Section 110 ...
Georgia (14-2, 2-1 SEC) crashed into the rankings by beating then-No. 6 Kentucky 82-69 on Jan. 7 and then-No. 17 Oklahoma 72-62 on Saturday. Tennessee (15-1, 2-1) represents another stiff ...