Increasingly it isn&#x27;t Ireland, but China or some other big economy where the money is made with their own incompatible taxation systems (you can deduct &quot;foreign taxes paid&quot; but not necessarily other cost of doing business fees that exist in lieu of taxes).<p>Effective double taxation is definitely possible when one tries to tax worldwide income, leading to a competitive disadvantage for American companies compared to their non-American competitors (e.g. IBM vs. SAP). So the US government introduces these loopholes to even the playing field, which are easily gamed and lead to abuses.