First, the United States has the most aggressive system for taxing foreign income after the 2017 TCJA. Just because income is not taxed in Ireland doesn’t mean it’s not taxed in the US. Currently US companies are required to include deemed dividends in US taxable income based on the net income of its foreign subsidiaries under the GILTI regime. This deemed inclusion is subject to a potential 50% deduction and the US tax can be reduced by foreign tax credits.
This Microsoft example is a horrible example as majority of the profits relates to a bullshit accounting gain from the liquidation of the certain subsidiaries of the company. Under the US system, there is likely zero taxable income because generally the liquidations of corporate subs into a parent company is tax free.
Prior to the TCJA, the Irish company with Bermuda residency generated sizable tax benefits; however, under the current system, it’s likely subject to 10.5% US income tax. One can certainly argue if the rate is too low, etc.