On 6 September 2016, Ireland's Department of Finance issued a release announcing proposed amendments to Section 110 of the Taxes Consolidation Act 1997 to address tax avoidance issues. Section 110 provides the tax regime for special purpose companies established to securitize assets, and if structured correctly can achieve a tax neutral position. According to the release, the special purpose regime has had the intended effect of improving Ireland’s offering as a location for the conduct of financial services, but has also has the unintended effect of being used to avoid paying tax on certain Irish property transactions. To resolve the...