Tony Killeen (Clare, Fianna Fail)

On 22 October last President Bush signed into law the American Jobs Creation Act of 2004, which provides for the amnesty in question. It gives US multinationals a one-off chance to repatriate to the US accumulated profits held outside the US, by availing of a special effective corporate tax rate of 5.25%. Non-US profits repatriated to the US are normally taxed at between 35% and 40%. As the legislation has just been signed into law, full details of how it will be interpreted by the US Inland Revenue Service and implemented in practice are not yet available. I have been informed that IDA Ireland is not overly concerned that this one-off opportunity to repatriate accumulated profit in the US will affect the level of ongoing US investment in Ireland. Companies committed to existing spending plans can still avail of the US opportunity and proceed with existing investment openings. However, given the significance of US investment to Ireland, IDA Ireland will manage it over the coming months. As part of the process, IDA Ireland and Forfás will undertake a joint review of the legislation, the possible implications for Irish foreign direct investment and how it is structured.

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