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This isn't really a new strategy. Putting your intellectual property in an offshore entity and paying royalties to the offshore entity goes back a long way. I recall the case of Geoffrey the Giraffe (the Toys R Us mascot) who resided in Bermuda for tax purposes. This resulted in some litigation, actually at the state tax level, as I recall, but I don't have all the details at hand.

And many computer tech companies have some sort of base (on paper at least) in Ireland for the same reason. Now many computer companies have a large physical physical presence in Ireland for other reasons as well. Ireland has favorable tax laws, an educated workforce, and they speak English as a native language.

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