 To get around this, the U.S. corporation needs to create a second Irish company (IRL2, or A), legally incorporated in Ireland (so under the U.S. tax code it is Irish), but which is "managed and controlled" from Bermuda (so under the Irish tax code it is from Bermuda).IRL2 will be placed between BER1 and IRL1 (i.e.owned by BER1, and owning IRL1).