The Corporate Anti-Inversion Rules- Don’t Leave Home Without Understanding Them
By Anthony Diosdi For some time, corporate inversion transactions have been the focus of Congress and has generated a vigorous political debate. This is in part because of concern by some members of Congress that the tax savings arising from inversion transactions were causing U.S. multinational corporate groups to shift business operations, manufacturing plants, and jobs abroad, with a resulting adverse effect on U.S. job opportunities and the overall U.S. economy. In today’s rapidly growing and changing economy, the practice of “inverting” is no longer restricted to multinational corporations. Smaller companies are considering expatriating from the United States. To combat the practice of “inverting,” Congress has enacted a number of Internal Revenue Code provisions. This article will discuss the different types of inversions that can be used by corporations and…