
The Corporate Anti-Inversion or Expatriation Rules Explained in a Nut-Shell
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 large multinational corporations. Smaller companies also are also involved in so-called “corporate inversion” or “corporate expatriation” transactions. This article will discuss the “nuts and bolts” of the corporate anti-inversion rules. Transactions Involving at Least 80 Percent Identity of Stock OwnershipThe anti-inversion rules are…