Just three years ago, as the public became aware that vulture funds were using everything from charities to securitisation vehicles to wipe staggering sums off their tax bills, the government was forced to step in and shut down the various, interrelated loopholes. The state had known about the issue for years, blithely ignoring the sharp practice on the basis that it was better to get investment in first, and worry about the tax implications later. Indeed, Nama had even offloaded loans to funds having been expressly told that the sale involved the use of Section 110 structures. Many law firms…

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