When the Irish treasury subsidiary of an overseas manufacturing group gained €200 million thanks to a loan waiver, the company declared this as non-taxable income. This led to a major test case.
Roadbridge has long carried heavy debts by industry standards. And it is now in talks with Bank of Ireland over the facilities.
Irish banks and vulture funds' instincts for debt enforcement litigation are seemingly dormant, except for one fund which may be running out of time.
After changing hands twice, the debt of farmers who had borrowed from ACC ended up in a dual structure set up by CarVal under new rules governing Section 110 companies. How successful has it been in reducing the vulture fund’s Revenue bills?
The financial crisis and its fall-out exposed the egregious securitisation of high-risk home loans and the exploitation of Irish tax loopholes by global vulture funds. A recent deal unveiled by The Currency last week brings back the memories.
CarVal agreed to buy €800m worth of home loans from Ulster Bank two years ago. In the process, the US vulture fund has now revealed the discount obtained, its tax strategy – and the risk it sees Sinn Féin posing to its investors.
When the Double Irish was shuttered, it was replaced with the Green Jersey and the utilisation of intercompany debt structures. It fits a familiar pattern: when one tax loophole closes, another one is usually prised open.
The Dublin vehicle established by Cerberus to digest property-backed debt with a face value of £1.4 billion in Northern Ireland has come to the end of its life, revealing how much profit the US vulture fund has drawn from the deal.
New financial information adds complexity to the structure of loans advanced by investors in National Broadband Ireland, whose chairman David McCourt is now separately borrowing against related assets.
It might not be immediately obvious but there is a strong link between the Glasgow climate conference and the Central Bank's mortgage rules. It is time to include energy efficiency and commuting factors into the real cost of a mortgaged property – not to mention their value to wider society.
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