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Corporate Inversions Rules And Strategies
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Book Synopsis Corporate Inversions : Rules and Strategies by : J.G.S. Yang
Download or read book Corporate Inversions : Rules and Strategies written by J.G.S. Yang and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article investigates the American phenomenon "corporate inversion" and how much income tax the strategy can actually save. It further explains the inversion rules and offers tax planning strategies to reduce a corporation's tax burden.
Book Synopsis The Evolution of Inversion Strategies by : Naveen Khanna
Download or read book The Evolution of Inversion Strategies written by Naveen Khanna and published by . This book was released on 2019 with total page 57 pages. Available in PDF, EPUB and Kindle. Book excerpt: Firms invert either through a pure inversion strategy or by merging with a foreign entity. We document that the impact of corporate inversions on the cost of equity is significantly different between the two strategies. We find that pure inversions increase the cost of equity by 10%, whereas inversions through mergers decrease it by 13%. Although both inversion strategies increase the inverting firm's shareholder value, inversions through mergers appear to create more value. However, before the tax reform of 2004, which eliminated the tax savings from pure inversions, most inversions were pure, whereas after the tax reform most were done through mergers. This finding suggests that the tax reform had an unintended consequence of reducing a managerial agency problem by eliminating the less beneficial inversion option.
Book Synopsis Corporate inversions by : United States. Congress. House. Committee on Ways and Means
Download or read book Corporate inversions written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 2002 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :United States. Congress. Senate. Committee on Appropriations. Subcommittee on Treasury and General Government Publisher : ISBN 13 : Total Pages :72 pages Book Rating :4.:/5 (51 download)
Book Synopsis Corporate Inversion by : United States. Congress. Senate. Committee on Appropriations. Subcommittee on Treasury and General Government
Download or read book Corporate Inversion written by United States. Congress. Senate. Committee on Appropriations. Subcommittee on Treasury and General Government and published by . This book was released on 2003 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Reinterpreting Corporate Inversions by : Inho Andrew Mun
Download or read book Reinterpreting Corporate Inversions written by Inho Andrew Mun and published by . This book was released on 2018 with total page 69 pages. Available in PDF, EPUB and Kindle. Book excerpt: Corporate inversions have drawn outrage from all segments of society. In an inversion, a company reincorporates abroad to escape its U.S. tax burden. Regulators and academics have typically sought tax law solutions to curb tax inversions. However, the resulting tax regulations have been ineffective, while more radical tax reforms are not politically feasible. This Note argues that inversion is not a tax problem in isolation, but a problem of aligning tax paid with benefits conferred by a given country. By introducing non-tax dimensions into the equation, this Note refines the oft-ignored benefit tax theory. The benefit tax theory proposes that the U.S. corporate tax regime accounts for superior legal and nonlegal benefits that companies enjoy by incorporating or operating in the United States. While paying U.S. tax, corporations receive the benefits of corporate governance, securities regulation, intellectual property law, and other areas of law; furthermore, benefits include many nonlegal business factors such as access to a large consumption market, skilled labor pool, capital markets, and more.This Note classifies the relevant benefits into three categories: Type I benefits, which corporations enjoy regardless of their place of incorporation or operation; Type II benefits, which corporations enjoy only if they are incorporated in the United States; and Type III benefits, which corporations enjoy by having operations in the United States. Using this classification, this Note builds a novel multi-dimensional regulatory competition model wherein countries compete across various legal and nonlegal dimensions, as opposed to the one-dimensional tax competition model on which inversion scholars have typically relied.The benefit tax theory and the multi-dimensional competition model illustrate that the problem with inversions is that corporations continue to take advantage of Type III benefits offered by the United States while paying lower tax elsewhere to a non-U.S. country. Inversion is problematic precisely because of the unbundling of certain Type III benefits from the rest of U.S. tax law. Understanding the inversion problem in this way leads to a clear solution: a better bundling of the U.S. tax law with the Type III benefits provided by the United States.
Book Synopsis Corporate Inversions and the Cost of Equity by : Tianpeng Zhou
Download or read book Corporate Inversions and the Cost of Equity written by Tianpeng Zhou and published by . This book was released on 2018 with total page 81 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures Publisher : ISBN 13 : Total Pages :80 pages Book Rating :4.0/5 ( download)
Book Synopsis Corporate inversions by : United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures
Download or read book Corporate inversions written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures and published by . This book was released on 2002 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :The Law The Law Library Publisher :Createspace Independent Publishing Platform ISBN 13 :9781729711156 Total Pages :122 pages Book Rating :4.7/5 (111 download)
Book Synopsis Inversions and Related Transactions (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) by : The Law The Law Library
Download or read book Inversions and Related Transactions (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) written by The Law The Law Library and published by Createspace Independent Publishing Platform. This book was released on 2018-11-09 with total page 122 pages. Available in PDF, EPUB and Kindle. Book excerpt: Inversions and Related Transactions (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Inversions and Related Transactions (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains temporary regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post-inversion tax avoidance transactions. These regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. The final regulations revise and add cross-references to coordinate the application of the temporary regulations. This book contains: - The complete text of the Inversions and Related Transactions (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Book Synopsis Tax Planning with Holding Companies - Repatriation of US Profits from Europe by : Rolf Eicke
Download or read book Tax Planning with Holding Companies - Repatriation of US Profits from Europe written by Rolf Eicke and published by Kluwer Law International B.V.. This book was released on 2009-01-01 with total page 526 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Author :Congressional Research Service Publisher :Createspace Independent Publishing Platform ISBN 13 :9781976517983 Total Pages :28 pages Book Rating :4.5/5 (179 download)
Book Synopsis Corporate Expatriation, Inversions, and Mergers by : Congressional Research Service
Download or read book Corporate Expatriation, Inversions, and Mergers written by Congressional Research Service and published by Createspace Independent Publishing Platform. This book was released on 2017-09-18 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt: News reports in the late 1990s and early 2000s drew attention to a phenomenon sometimes called corporate "inversions" or "expatriations" instances where U.S. firms reorganize their structure so that the "parent" element of the group is a foreign corporation rather than a corporation chartered in the United States. The main objective of these transactions was tax savings, and they involved little to no shift in actual economic activity. Bermuda and the Cayman Islands (countries with no corporate income tax) were the location of many of the newly created parent corporations. These types of inversions largely ended with the enactment of the American Jobs Creation Act of 2004 (JOBS Act, P.L. 108-357), which denied the tax benefits of an inversion if the original U.S. stockholders owned 80% or more of the new firm. The act effectively ended shifts to tax havens where no real business activity took place. However, two avenues for inverting remained. The act allowed a firm to invert if it has substantial business operations in the country where the new parent was to be located; the regulations at one point set a 10% level of these business operations. Several inversions using the business activity test resulted in Treasury regulations in 2012 that increased the activity requirement to 25%, effectively closing off this method. Firms could also invert by merging with a foreign company if the original U.S. stockholders owned less than 80% of the new firm. Two features made a country an attractive destination: a low corporate tax rate and a territorial tax system that did not tax foreign source income. Recently, the U.K. joined countries such as Ireland, Switzerland, and Canada as targets for inverting when it adopted a territorial tax. At the same time, the U.K. also lowered its rate (from 25% to 20% by 2015). Several high-profile companies had more recently indicated an interest in merging with a non-U.S. headquartered company, including Pfizer, Chiquita, AbbVie, and Burger King. This "second wave" of inversions again raises concerns about an erosion of the U.S. tax base. Chiquita and AbbVie have canceled their plans in the wake of new Treasury regulations, but Burger King and other firms are continuing merger plans. Pfizer subsequently terminated its planned merger with Allergan after Treasury regulations issued in 2016. Two policy options have been discussed in response: a general reform of the U.S. corporate tax and specific provisions to deal with tax-motivated international mergers. Some have suggested that lowering the corporate tax rate as part of broader tax reform would slow the rate of inversions. Although a lower rate would reduce the incentives to invert, it would be difficult to reduce the rate to the level needed to stop inversions, especially given the effect of the revenue loss on the budget. Other tax reform proposals suggest that if the United States moved to a territorial tax, the incentive to invert would be eliminated. There are concerns that a territorial tax could worsen the profit-shifting that already exists among multinational firms. The second option is to directly target inversions: H.R. 1931, H.R. 3434, and S. 1636 would treat all mergers as U.S. firms if the U.S. shareholders maintain control of the merged company, as well as impose other restrictions. S. 1673 would tax accumulated earnings of inverting firms. H.R. 1932 and S. 851 would include anti-inversion provisions as part of a broader proposal to address tax havens and deferral. H.R. 3603 would address earnings-stripping of inverted corporations. H.R. 3424 would disallow federal contracts for inverted firms. H.R. 1451 and S. 586 would make major changes in the tax treatment of foreign source income and tighten existing anti-inversion rules. On September 22, 2014, the Treasury announced regulatory measures to limit some of the benefits of inversions. Evidence from news accounts and statistical data suggest that inversions have declined.
Book Synopsis Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures and Other Strategic Alliances, Financings, Reorganizations and Restructurings by :
Download or read book Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures and Other Strategic Alliances, Financings, Reorganizations and Restructurings written by and published by . This book was released on 2005 with total page 1236 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Irrational Investors and the Corporate Inversion Puzzle by : Gregory Day
Download or read book Irrational Investors and the Corporate Inversion Puzzle written by Gregory Day and published by . This book was released on 2016 with total page 47 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite recent legislative and administrative efforts, U.S. corporations continue to engage in a controversial business strategy known as a “corporate inversion.” A U.S corporation performing an inversion must acquire a foreign corporation and then, through a series of complex transactions, restructures in the foreign corporation's country. In light of the United States' burdensome corporate tax code, the inversion process allows formally American corporations to become taxable as a foreign entity, generating sizable tax savings.It is seldom noticed, however, that the inversion trend raises a significant corporate law puzzle regarding the misaligned incentives dividing directors and shareholders. From a corporate director's point of view, inversions are particularly attractive. This is because the process can be structured to reduce a company's tax rate while also lessening management's duty to comply with costly regulatory frameworks. For instance, inverted companies often reincorporate in countries with more management-friendly corporate governance statutes. Likewise, since U.S. exchanges subject foreign incorporated companies to less scrutinizing securities regulations, the inversion process can allow publicly traded companies to minimize costly disclosure, auditing, and corporate governance requirements. But, critically, inversions are puzzling from an investor or shareholder's perspective. Since corporate regulations are generally thought to protect investors, why would an individual invest in a company that has deliberately sought out and reincorporated in a country that provides minimal shareholder protections? In fact, shareholders often vote in favor of, and thus authorize, the very transactions that limit their ability to acquire information and enforce other shareholder rights. So why is the corporate migration trend booming if individuals should disfavor investing in inverted companies and shareholders should refuse to authorize them? Do individuals value the law? Using an original dataset and empirical analysis, this Article explores why individuals appear to ignore something as important -- and as valuable -- as the law.
Book Synopsis Corporate Inversions by : Fredrick White
Download or read book Corporate Inversions written by Fredrick White and published by Nova Science Publishers. This book was released on 2014-12 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The U.S. corporate income tax is based on worldwide economic activity. If all of a corporation's economic activity is in the United States, then tax administration and compliance is, relatively, straight-forward. Many corporations, however, operate in several jurisdictions, which creates complications for tax administration and compliance. Further, corporations may actively choose where and how to organise to reduce their U.S. and worldwide tax liabilities. Some of these strategies have been referred to as expatriation, inversions, and mergers. This book examines them in light of recent expansion of their use and growing congressional interest. This book also focuses on the global issues relating to tax rate differentials between the United States and other countries. It provides tax rate comparisons; discusses policy implications, including the effect of a corporate rate cut on revenue, output, and national welfare; and discusses the outlook for and consequences of a revenue neutral corporate tax reform.
Book Synopsis Mergers, Acquisitions, and Other Restructuring Activities by : Donald DePamphilis
Download or read book Mergers, Acquisitions, and Other Restructuring Activities written by Donald DePamphilis and published by Academic Press. This book was released on 2017-07-12 with total page 772 pages. Available in PDF, EPUB and Kindle. Book excerpt: Mergers, Acquisitions, and Other Restructuring Activities: An Integrated Approach to Process, Tools, Cases, and Solutions, Ninth Edition, is the most current, comprehensive and cutting-edge text on M&A and corporate restructuring available. It includes many of the most up-to-date and notable deals and precedent setting judicial decisions, as well as new regulations, trends and tactics employed in M&As. The implications of recent developments such as negative interest rates on valuation and the backlash against globalization for cross-border M&As are discussed. More than 90% of the case studies are new for this edition, involving deals either announced or completed during the last several years. It is comprehensive in that nearly all aspects of M&As and corporate restructuring are explored from business plan development to target selection and valuation to negotiation and post-merger integration. It is cutting edge in that conclusions and insights are anchored by the most recent academic research, with references to more than 160 empirical studies published in leading peer-reviewed journals just since the release of the last edition in 2015. Teaches about the financial, legal, accounting and strategic elements of mergers and acquisitions by concentrating on the ways their agents interact Emphasizes current events and trends through new and updated cases Highlights international mergers and acquisitions activities
Author :The Law The Law Library Publisher :Createspace Independent Publishing Platform ISBN 13 :9781729711187 Total Pages :34 pages Book Rating :4.7/5 (111 download)
Book Synopsis Inversions and Related Transactions - Guidance for Determining Stock Ownership (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) by : The Law The Law Library
Download or read book Inversions and Related Transactions - Guidance for Determining Stock Ownership (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) written by The Law The Law Library and published by Createspace Independent Publishing Platform. This book was released on 2018-11-09 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt: Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These regulations also provide guidance on the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto) and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on Rules Regarding Inversions and Related Transactions in the Proposed Rules section of this issue of the Federal Register. This book contains: - The complete text of the Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Book Synopsis Tax Strategy Vs. Countermeasures by : Naoki Matsuda
Download or read book Tax Strategy Vs. Countermeasures written by Naoki Matsuda and published by Xlibris Corporation. This book was released on 2015-12-19 with total page 475 pages. Available in PDF, EPUB and Kindle. Book excerpt: In todays world, where it has become fairly easy for a taxpayer to move back and forth from one country to another, it has become quite a common tax strategy, especially among wealthy individuals and multinational companies, to transfer their residence, income, and assets abroad mainly to reduce tax burden. Particularly in Europe, many wealthy individuals have moved their residence abroad mostly for tax purpose. Thus, tennis legend Bjorn Borg, who was known to have transferred decades ago his residence from Sweden to Monaco, is obviously not alone. A more recent, well-publicized case was Grard Depardieu, who showed his intention of leaving France after having acquired Russian citizenship in 2013. This famous French actor and entrepreneur is reported to have made a comment that the French governments recent plan of raising the top marginal individual income tax rate is just like penalizing talented people who have achieved success in their careers.
Book Synopsis Tax, Inequality, and Human Rights by : Philip G. Alston
Download or read book Tax, Inequality, and Human Rights written by Philip G. Alston and published by Oxford University Press. This book was released on 2019-04-11 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: For the first time, Human Rights and Tax in an Unequal World brings together works by human rights and tax law experts, to illustrate the linkages between the two fields and to reveal their mutual relevance in tackling economic, social, and political inequalities. Against the backdrop of systemic corporate tax avoidance, the widespread use of tax havens, persistent pressures to embrace austerity policies, and growing gaps between the rich and poor, this book encourages readers to understand fiscal policy as human rights policy, with profound consequences for the wellbeing of citizens around the world. The essays collected examine where the foundational principles of tax law and human rights law intersect and diverge; discuss the cross-border nature and human rights impacts of abusive practices like tax avoidance and evasion; question the role of states in bringing transparency and accountability to tax policies and practices; highlight the responsibility of private sector actors for the consequences of tax laws; and critically evaluate certain domestic tax rules through the lens of equality and non-discrimination. The contributing scholars and practitioners explore how an international human rights framework can anchor debates around international tax reform and domestic fiscal consolidation in existing state obligations. They address what human rights law requires of state tax policies, and what a state's tax laws and loopholes mean for the enjoyment of human rights within and outside its borders. Ultimately, tax and human rights both turn on the relationship between the individual and the state, and thus both fields face crises as the social contract frays and populist, illiberal regimes are on the rise.
