Task: Question Generation
Input (English): Context_1 : Commissioner v. Sunnen, 333 U.S. 591 (1948), was a case decided by the Supreme Court of the United States in 1948 in which the Court outlined the scope of collateral estoppel or estoppel by judgment in determinations of federal tax liability. This was important because a single controversial circumstance may have a bearing on income tax liability for several years. Res judicata, as part of the doctrine of judicial finality, protects a taxpayer's tax liability for a given year once the taxpayer wins a judgment in court. The judgment is controlling not only controlling with regard to the issues litigated but also with any issues that "could have" been raised if they would have affected the determination of tax liability for the year. However, of course, a single controversial circumstance may have a bearing on income tax liability for several years, and if a judgment fixes liability for one of the years, res judiciary forecloses the reopening of only that year's liability. But the related doctrine of collateral estoppel prevents relitigation of issues that were in fact raised and decided in the earlier litigation, even when they arise in a new cause of action, such as a dispute as to liability for a later year. Context_2 : The European Union value added tax (or EU VAT) is a value added tax on goods and services within the European Union (EU). The EU's institutions do not collect the tax, but EU member states are each required to adopt a value added tax that complies with the EU VAT code. Different rates of VAT apply in different EU member states, ranging from 17% in Luxembourg to 27% in Hungary. The total VAT collected by member states is used as part of the calculation to determine what each state contributes to the "EU's budget". Context_3 : A permanent establishment (PE) is a fixed place of business which generally gives rise to income or value-added tax liability in a particular jurisdiction. The term is defined in many income tax treaties and in most European Union Value Added Tax systems. The tax systems in some civil-law countries impose income taxes and value-added taxes only where an enterprise maintains a PE in the country concerned. Definitions of PEs under tax law or tax treaties may contain specific inclusions or exclusions. Context_4 : The Kepner Income Tax is an approach to taxation, suggested in the United States, that would collect on a progressive income tax (with no deductions, credits or exemptions) and an estate tax. It would repeal the corporate tax and payroll taxes (including Federal Insurance Contributions Act tax (FICA)). All income, from whatever source, would be taxed the same (i.e., whether income from wages, dividends, interest or capital gains). The plan was proposed by Hayden Kepner of the law firm Arnall Golden Gregory. Kepner states that such a tax system would be transparent, easily understandable, could fit on a post-card, and everyone who earns an income would pay taxes. The plan would expand the tax base and he suggests that it would have an incentive to keep federal spending at modest levels (under our current system, approximately 50% pay no income taxes and may not have the incentive to try to keep federal spending in control). The personal income tax would be made up of three progressive rates: 15%, 25%, and 35% (locked together to prevent raising of one rate without raising the others). The estate tax would apply an annual wealth tax of 1-2%, which would be similar to property taxes currently administered at the state level, but would include all property (i.e., stocks, bonds, real property) above a threshold amount. Context_5 : Taxes in Spain are levied by national (federal), regional and local governments. Tax revenue in Spain stood at 36.3% of GDP in 2013. A wide range of taxes are levied on different sources, the most important ones being income tax, social security contributions, corporate tax, value added tax; some of them are applied at national level and others at national and regional levels. Most national and regional taxes are collected by the Agencia Estatal de Administración Tributaria which is the bureau responsible for collecting taxes at the national level. Other minor taxes like property transfer tax (regional), real estate property tax (local), road tax (local) are collected directly by regional or local administrations. Four historical territories or foral provinces (Araba/Álava, Bizkaia, Gipuzkoa and Navarre) collect all national and regional taxes themselves and subsequently transfer the portion due to central Government after two negotiations called Concierto (in which the first three territories, that conform the Basque Autonomous Community, agree their defense jointly) and the Convenio (in which the territory and Community of Navarre defense itself alone). The tax year in Spain follows the calendar year. The tax collection method depends on the tax; some of them are collected by self-assessment, but others (i.e. income tax) follow a system of pay-as-you-earn tax with monthly withholdings that follow a self-assessment at the end of the term. Context_6 : In Ireland there is an income tax, a value added tax (VAT), and various other taxes. Employees pay pay-as-you-earn (PAYE) taxes based on their income, less certain allowances. The taxation of earnings is progressive, with little or no income tax paid by low earners and a high rate applied to middle to top earners, the top marginal rate of tax (including USC and PRSI) is 52%. However a large proportion of central government tax revenue is also derived from VAT, excise duties and other taxes on consumption. The standard rate of corporation tax is among the lowest in the world at 12.5%. Context_7 : Taxes in Bulgaria are collected on both state and local levels. The most important taxes are collected on federal level, these taxes include an income tax, social security, corporate taxes and value added tax. On local level property taxes as well as various fees are collected. All income earned in Bulgaria is taxed on a flat rate of 10%. Employment income earned in Bulgaria is also subject to various social security insurance contributions. In total the employee pays 12.9% and the employer contributes what corresponds to 17.9%. Corporate income tax is also a flat 10%. Value-Added Tax applies at a flat rate of 20% on virtually all goods and services. A lower rate of 9% applies on only hotel services. Context_8 : The double Irish arrangement is a tax strategy that some multinational corporations used to lower their corporate tax liability. The strategy has ceased to be available since 1 January 2015, though those already engaging in the arrangement have until 2020 to find another arrangement. The strategy used payments between related entities in a corporate structure to move income from a higher-tax country to a lower or no tax jurisdiction. It relies on the fact that Irish tax law does not include transfer pricing rules as does the United States and those of many other jurisdictions. Specifically, Ireland has territorial taxation, and does not levy taxes on income booked in subsidiaries of Irish companies that are outside the state. Context_9 : The Competitive Tax Plan is an approach to taxation, suggested in the United States, that would impose a 10–15% value added tax (VAT) and reduce personal and corporate income taxes. The plan was created by Michael J. Graetz, professor at Columbia law school, and a former Deputy Assistant Secretary of the Treasury for Tax Policy. Graetz states that it would generate enough revenue so that families with $100,000 of annual income or less — almost 90% of all current filers — would not have to pay income taxes or file tax returns. Graetz would provide a new payroll tax offset to replace the Earned Income Tax Credit and to protect low and moderate income workers from any tax increase under the new system. Under the initial proposal, households with an annual income of more than $100,000 would be taxed at a flat 25% rate and the corporate income tax rate would be reduced to 25%. Graetz argues that reducing the corporate tax rate "would make the United States an extremely attractive nation for corporate investments for both U.S. citizens and foreign investors". According to an article in the November 19, 2002 issue of "The Wall Street Journal", the Competitive Tax Plan is already being given consideration by officials in the United States Treasury Department. In 2013, Graetz presented an updated version of his plan for 2015. In it, he proposed progressive income tax rates for single filers making over $50,000 and households making over $100,000 ($75,000 for head of household) and lowering the corporate income tax further, to 15%. Context_10 : In Latvia, taxes are levied by both national and local governments. Tax revenue stood at 28.1% of the GDP in 2013. The most important revenue sources include income tax, social security, corporate tax and value added tax, which are all applied on the national level. Income taxes are levied at a flat rate of 23% on all income. A long range of tax allowances is given including a standard allowance of €900 per year and €1980 per year for every dependent. fact_1 :  It relies on the fact that Irish tax law does not include transfer pricing rules as does the United States and those of many other jurisdictions. fact_2 : In Ireland there is an income tax, a value added tax (VAT), and various other taxes. Answer: Irish tax law
Output (English): The double Irish arrangement is a tax strategy, that some multinational corporations used to lower their corporate tax liability, it relies on the fact that Irish tax law does not include transfer pricing rules as does the United States and those of many other jurisdictions, the standard rate of corporation tax is among the lowest in the world at 12.5, in Ireland there is an income tax, a value added tax VAT, and various other taxes, is called?