Irish Prime Minister Simon Harris said his country has “exciting opportunities” as it considers how to spend an almost €14 billion ($15.4 billion) windfall it will receive as a result of Apple Inc. losing a European court fight over its tax bill.
“This is a situation where we do have finality, we will have about 14 billion and there are exciting opportunities as to how we can invest that in the infrastructure for future generations,” he said Thursday on RTE radio.
On Tuesday, the European Union’s Court of Justice in Luxembourg backed a landmark 2016 decision that Ireland broke state-aid laws by giving the company tax benefits that resulted in an unfair advantage.
The Irish government has always maintained that it didn’t think Apple owed these taxes and denied having given the tech giant any preferential treatment, but the money involved has been sitting in escrow since the initial 2016 ruling.
Ireland is now in the enviable position of having a windfall to spend that is the equivalent of 14% of government spending this year, or some €2,700 for every man, woman and child in the country.
“I don’t want to get into specific projects because I do want government to make a considered and informed decision on this. But there is an opportunity here,” said Harris.
The money will take a few months to be transferred to the Irish exchequer, said Harris, adding that he isn’t aware of any other claims to it.
Ireland is grappling with a housing crisis caused by a shortage in supply, along with other infrastructure issues. “When it comes to things like housing, water and energy, there are real constraints in this country and we need to invest in them,” said Harris.
The Apple funds won’t be part of the upcoming budget, he added. “It cannot be spent on day to day, for example you can’t put it in the state pension,” he said. “You only get this money once.”
The funds have been accruing interest since the bill was paid by Apple into the escrow account. The Irish government said in July the total value of the fund stands at €13.8 billion, after generating €400 million in 2023.
The Irish government has come in for criticism from opposition parties that it had sided with Apple and fought the court case.
“Any responsible government would stand by the independence of its tax system and its revenue system,” Harris said in defending the stance. “Six thousand people in Ireland are employed by Apple today. Hundreds of thousands of people are going to work in multinational companies the length and breadth of this country. And actually standing by multinationals and tax policy is an important thing.”
The Financial Accounting Standards Board issued a proposed accounting standards update Tuesday to establish authoritative guidance on the accounting for government grants received by business entities.
U.S. GAAP currently doesn’t provide specific authoritative guidance about the recognition, measurement, and presentation of a grant received by a business entity from a government. Instead, many businesses currently apply the International Financial Reporting Standards Foundation’s International Accounting Standard 20, Accounting for Government Grants and Disclosure of Government Assistance, by analogy, at least in part, to account for government grants.
In 2022 FASB issued an Invitation to Comment, Accounting for Government Grants by Business Entities—Potential Incorporation of IAS 20, Accounting for Government Grants and Disclosure of Government Assistance, into GAAP. In response, most of FASB’s stakeholders supported leveraging the guidance in IAS 20 to develop accounting guidance for government grants in GAAP, believing it would reduce diversity in practice because entities would apply the guidance instead of analogizing to it or other guidance, thus narrowing the variability in accounting for government grants.
The proposed ASU would leverage the guidance in IAS 20 with targeted improvements to establish guidance on how to recognize, measure, and present a government grant including (1) a grant related to an asset and (2) a grant related to income. It also would require, consistent with current disclosure requirements, disclosure about the nature of the government grant received, the accounting policies used to account for the grant, and significant terms and conditions of the grant, among others.
FASB is asking for comments on the proposed ASU by March 31, 2025.
“It will not be a cut and paste of IAS 20,” said FASB technical director Jackson Day during a session at Financial Executives International’s Current Financial Reporting Insights conference last week. “First of all, the scope is going to be a little bit different, probably a little bit more narrow. Second of all, the threshold of recognizing a government grant will be based on ‘probable,’ and ‘probable’ as we think of it in U.S. GAAP terms. We’re also going to do some work to make clarifications, etc. There is a little bit different thinking around the government grants for assets. There will be a deferred income approach or a cost accumulation approach that you can pick. And finally, there will be different disclosures because the disclosures will be based on what the board had previously issued, but it does leverage IAS 20. A few other things it does as far as reducing diversity. Most people analogized IAS 20. That was our anecdotal findings. But what does that mean? How exactly do they do that? This will set forth the specifics. It will also eliminate from the population those that were analogizing to ASC 450 or 958, because there were a few of those too. So it will go a long way in reducing diversity. It will also head down a model that will be generally internationally converged, which we still think about. We still collaborate with the staff [of the International Accounting Standards Board]. We don’t have any joint projects, but we still do our best when it makes sense to align on projects.”
Mauled Again (http://mauledagain.blogspot.com/): Not long ago, about a dozen states would seize property for failure to pay property taxes and, instead of simply taking their share of unpaid taxes, interest, and penalties and returning the excess to the property owner, they would pocket the entire proceeds of the sales. Did high court intervention stem this practice? Not so much.
Current Federal Tax Developments (https://www.currentfederaltaxdevelopments.com/): In Surk LLC v. Commissioner, the Tax Court was presented with the question of basis computations related to an interest in a partnership. The taxpayer mistakenly deducted losses that exceeded the limitation in IRC Sec. 704(d), raising the question: Should the taxpayer reduce its basis in subsequent years by the amount of those disallowed losses or compute the basis by treating those losses as if they were never deducted?
Parametric (https://www.parametricportfolio.com/blog): If your clients are using more traditional commingled products for their passive exposures, they may not know how much tax money they’re leaving on the table. A look at possible advantages of a separately managed account.
Turbotax (https://blog.turbotax.intuit.com): Whether they’re talking diversification, gainful hobby or income stream, what to remind them about the tax benefits of investing in real estate.
The National Association of Tax Professionals (https://blog.natptax.com/): Q&A from a recent webinar on day cares’ unique income and expense categories.
Boyum & Barenscheer (https://www.myboyum.com/blog/): For larger manufacturers, compliance under IRC 263A is essential. And for all manufacturers, effective inventory management goes beyond balancing stock levels. Key factors affecting inventory accounting for large and small manufacturing businesses.
Withum (https://www.withum.com/resources/): A look at the recent IRS Memorandum 2024-36010 that denied the application of IRC Sec. 245A to dividends received by a controlled foreign corporation.
PwC made a $1.5 million investment to Bryant University, in Smithfield, Rhode Island, to fund the launch of the PwC AI in Accounting Fellowship.
The experiential learning program allows undergraduate students to explore AI’s impact in accounting by way of engaging in research with faculty, corporate-sponsored projects and professional development that blends traditional accounting principles with AI-driven tools and platforms.
The first cohort of PwC AI in Accounting Fellows will be awarded to members of the Bryant Honors Program planning to study accounting. The fellowship funds can be applied to various educational resources, including conference fees, specialized data sheets, software and travel.
“Aligned with our Vision 2030 strategic plan and our commitment to experiential learning and academic excellence, the fellowship also builds upon PwC’s longstanding relationship with Bryant University,” Bryant University president Ross Gittell said in a statement. “This strong partnership supports institutional objectives and includes the annual PwC Accounting Careers Leadership Institute for rising high school seniors, the PwC Endowed Scholarship Fund, the PwC Book Fund, and the PwC Center for Diversity and Inclusion.”
Bob Calabro, a PwC US partner and 1988 Bryant University alumnus and trustee, helped lead the development of the program.
“We are excited to introduce students to the many opportunities available to them in the accounting field and to prepare them to make the most of those opportunities, This program further illustrates the strong relationship between PwC and Bryant University, where so many of our partners and staff began their career journey in accounting” Calabro said in a statement.
“Bryant’s Accounting faculty are excited to work with our PwC AI in Accounting Fellows to help them develop impactful research projects and create important experiential learning opportunities,” professor Daniel Ames, chair of Bryant’s accounting department, said in a statement. “This program provides an invaluable opportunity for students to apply AI concepts to real-world accounting, shaping their educational journey in significant ways.”