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Corporate Expatriation, Inversions, and Mergers : Tax Issues

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Summary

Discusses Congressional interest in recent expansion of U.S. firms use of "inversion" or "expatriation" to alter their corporate structure by substituting a foreign parent corporation for a domesti...

Discusses Congressional interest in recent expansion of U.S. firms use of "inversion" or "expatriation" to alter their corporate structure by substituting a foreign parent corporation for a domestic one to save substantial amounts of corporate-level U.S. income taxes. Reviews relevant portions of U.S. corporate income tax system, and examines how inversions are commonly structured. Explains how Congress and Department of Treasury have reduced the benefits of inversions. Considers inversion methods that remain and policy options available to prevent or limit these inversions.

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