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News : Property Last Updated: Jan 9, 2015 - 8:42 AM


Biggest US individual landowner responds to tax breaks in Ireland and UK
By Michael Hennigan, Finfacts founder and editor
Nov 3, 2014 - 12:39 PM

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Humewood Castle, County Wicklow Source: Sherry FitzGerald

In recent years, the biggest US individual landowner has taken advantage of tax breaks in Ireland to buy cheap Irish property assets tax-free and to change the tax residency of his key holding company from the US to the UK, saving over a billion dollars in taxes.

John Malone, who controls Liberty Global, the owner of UPC Ireland, the broadband and TV cable operator, last year had the tax residency of one of the leading US cable companies transferred from Colorado to London in what is termed a tax inversion.

According to an investigation by Jesse Drucker of Bloomberg News, Malone made a personal tax saving of $200m through using trusts and Liberty saved more than $1bn in taxes.

Malone who is estimated to be worth $7.5bn has land holdings of about 2.2m acres in the US and he was incentivised to invest in Irish property by a tax break that was introduced by Michael Noonan, finance minister, in 2011.

The tax break exempts capital gains tax on properties purchased after December 07, 2011 and before the end December 2013.

The break was extended to the end of 2014 and Noonan announced in Budget 2015 last month that it would be no longer available for new investments after January 01, 2015.

Malone with partners bought three Dublin hotels: the Westin, the Trinity Capital Hotel and the Hilton Dublin, for €130m and he paid €8m for Humewood Castle in County Wicklow, south of Dublin.

Humewood, which was built in the 1860s and includes over 420 acres of land, was sold in 2006 for €25m to a developer, according to the Irish Times

Related tax links

Apple says it may have to pay Ireland back tax; Foreign tax rate at 4.4%

Double Irish tax scheme axed; Conventional wisdom wrong again - Part 1

Replacing the Double Irish with Knowledge Development / Patent Box - Part 2

Ireland's small gain from Apple's possible EU tax probe payment

European Commission: Apple given special tax deals by Ireland

Apple's foreign tax rate tumbled after 2007 Irish 'advanced opinion'

G20 finance ministers reaffirm commitment to tax reform; Ibec takes Finfacts' advice

OECD & Tax: Everything grand in Ireland's Republic of Spin?

OECD proposes biggest reform of global business tax rules since 1920s

Finfacts submission to Department of Finance consultation on corporation tax reform

OECD BEPS Project submission from Finfacts: Ireland should embrace corporate tax reform

Irish corporate tax policy like property bubble driven by short-term interests

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