The end result is that from the viewpoint of the United States tax authorities, “Ireland Limited” and “Google BV” do not exist, but for Europe they are real. For Ireland, “Google Holdings” is Bermudian but for the United States it is Irish. Playing tax treaties against each other—and in particular exploiting their inconsistent definitions of residency—Google thus generates stateless income, nowhere taxed in the year it is generated (Kleinbard 2011, 2012, 2013). In recent years, according to Google’s company filings, its effective tax rate on foreign profits has ranged from
2 to 8 percent.