Where the math is defensible.
Long-form research on live enterprise decisions. Publication is selective. Every number traces to a named source. No takes without evidence.
Bermuda Reinsurance Through 2026: Pillar Two, Cat Capacity, and the Florida Pivot
The world's largest reinsurance hub absorbed Helene, Milton, and the January 2025 LA wildfires, raised roughly 18 billion dollars of new Class 4 capital, and on January 1, 2025 began collecting a 15 percent corporate income tax to comply with OECD Pillar Two. The question for 2026 is whether the BMA's Solvency Capital Requirement framework, the Bermuda Triangle capital cycle, and a 50 billion dollar cat bond market can keep clearing US peak peril risk at acceptable margins after the tax wedge.
Bermuda is the central node of global property catastrophe reinsurance. The Bermuda Monetary Authority's 2024 statistical review reports gross premiums written by Bermuda commercial reinsurers above 230 billion dollars, with the island clearing roughly one third of global property and casualty reinsurance capacity and a majority of US pea...
Ireland at Fifteen Percent: The Pillar Two Transition and the Stickiness of the Cluster
The 12.5 percent rate that built modern Ireland is gone for the largest multinationals, replaced by a 15 percent floor enforced through QDMTT and IIR. Corporate tax receipts kept climbing through the transition. The question is whether agglomeration outlasts arbitrage.
Ireland transposed EU Council Directive 2022/2523 through Part 4A of the Taxes Consolidation Act 1997, inserted by the Finance (No. 2) Act 2023. From accounting periods beginning on or after 31 December 2023, Irish constituent entities of multinational groups with consolidated revenue at or above EUR 750 million pay an effective 15 percen...
Ireland's Corporation Tax Windfall and the Future Ireland Fund: Sovereign Savings Against a Concentrated Base
The 13.0 billion euro Apple State Aid disbursement and a 27.8 billion euro 2024 corporation tax take pushed Ireland's headline surplus to 25.0 billion euro, but the Irish Fiscal Advisory Council estimates that ten firms generate 56 percent of receipts. The Future Ireland Fund and the Infrastructure, Climate and Nature Fund are the policy answer for the 2025 to 2035 window, and Pillar Two and US tariff risk are the live threats.
Ireland's exchequer collected 27.8 billion euro in corporation tax in 2024, equal to 33 percent of total tax revenue, with an additional 14.1 billion euro in Apple back taxes plus interest received in tranches under the Court of Justice of the European Union ruling in C-465/20 of September 10, 2024. The 2024 general government surplus rea...
The TCJA Cliff and OBBBA: US Fiscal Trajectory Through 2026
Most individual provisions of the 2017 Tax Cuts and Jobs Act sunset on December 31, 2025. The One Big Beautiful Bill Act, signed July 4, 2025, made the bulk of those provisions permanent at a CBO-scored cost of roughly 4.5 trillion dollars over ten years. The fiscal trajectory through 2026 is now defined by debt-to-GDP, term premium, distributional incidence, and state-level conformity friction.
The Tax Cuts and Jobs Act of 2017, Public Law 115-97, scheduled most of its individual income tax provisions to sunset on December 31, 2025. The corporate side, including the 21 percent flat corporate rate, GILTI, FDII, and BEAT, was made permanent in 2017. The One Big Beautiful Bill Act, Public Law 119-21, signed by President Trump on Ju...