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Google bills most non US clients from Google Ireland too. Obviously there are tax considerations. But Google (non US) and Linkedin genuinely have big presences in Ireland. They do account management, customer service, accounting, etc out of massive Dublin offices. Language, availability of educated generalists and willingness of European employees to immigrate to Dublin are also big considerations. They aren't billing to shell companies.

This is a genuine loophole that is being closed, not an intentional piece of policy.



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