John Sokatch (J.D. 2012, SMU), Transfer-Pricing With Software Allows for Effective Circumvention of Subpart F Income: Google's "Sandwich" Costs Taxpayers Millions, 45 Int'l Law. 725 (2011)::

Part I of this paper compares international corporate taxation rates to U.S. rates to provide a comprehensive understanding of why companies like Google would elect to utilize transfer pricing and shift profits from U.S. soil. Part II explains the ―Double Irish‖ and ―Dutch Sandwich‖ tax maneuvers and how Google implements these strategies to legally lower their effective corporate tax rates to minimal levels. Part III examines various legal measures that the U.S. government has enacted to counter-balance such practices and bring profits back within U.S. borders. It also examines the possible solutions to the problem with commentary on why amendments to the current taxation regime are necessary.

While the extent to which the global economy is affected by avoidance maneuvers implemented by Google and other similarly situated companies remains unclear, such maneuvers may eventually become commonplace practices for average-size businesses. Moreover, while some commentators claim that Google is ignoring its corporate slogan, ―Don‘t be evil,‖ by the creation of such a scheme,19 these tax maneuvers may signify a more disturbing and potentially detrimental future for international bodies choosing to ignore such on-goings while the rest of the world embraces the ever-changing landscape and globalization of international business transactions.