New Inversions, the 'Joe Frazier Left Hook,' the IRS Notice, and Pfizer

12 Pages Posted: 20 Aug 2014 Last revised: 8 Oct 2014

See all articles by Samuel C. Thompson, Jr.

Samuel C. Thompson, Jr.

The Pennsylvania State University (University Park) – Penn State Law

Date Written: June 23, 2014

Abstract

This article discusses the “New Inversions” many U.S. firms are engaging in, as illustrated by the acquisition by a newly formed Irish holding company of the stock of (1) Endo, a U.S. firm and the real acquirer, and (2) Paladin, a Canadian firm and the real target. The article shows how these transactions are rendering a “Joe Frazier Left Hook” to the Treasury’s “Killer B” regulations even after the issuance by the IRS of Notice 2014-32 on April 25, 2014. The article then explores how “Ali” (a.k.a. Treasury) and the Congress can punch back against these transactions.

Keywords: Inversions, corporate tax, international tax, mergers and acquisitions

JEL Classification: H25

Suggested Citation

Thompson, Jr., Samuel C., New Inversions, the 'Joe Frazier Left Hook,' the IRS Notice, and Pfizer (June 23, 2014). Tax Notes, 2014, Penn State Law Research Paper No. 37-2014, Available at SSRN: https://ssrn.com/abstract=2482663

Samuel C. Thompson, Jr. (Contact Author)

The Pennsylvania State University (University Park) – Penn State Law ( email )

Lewis Katz Building
University Park, PA 16802
United States

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