Download This PaperThe Cat-and-Mouse Inversion Game with Burger King
10 Pages Posted: 12 Oct 2014 Last revised: 1 Nov 2014
Date Written: September 15, 2014
Abstract
With inversions, taxpayers and the Treasury are playing a game of Cat and Mouse. The partnership structure employed in the Burger King-Tim Hortons inversion is the latest twist in this game, and indeed, the Mouse seems to be taunting the Cat. This article discusses the structure of the partnership that is used to give electing Burger King shareholders tax-free treatment and explains why the Treasury should challenge the transaction.
Suggested Citation: Suggested Citation
Thompson, Jr., Samuel C., The Cat-and-Mouse Inversion Game with Burger King (September 15, 2014). Tax Notes, Vol. 144, No. 11, 2014, Penn State Law Research Paper No. 43-2014, Available at SSRN: https://ssrn.com/abstract=2508453
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