The Cat-and-Mouse Inversion Game with Burger King

10 Pages Posted: 12 Oct 2014 Last revised: 1 Nov 2014

See all articles by Samuel C. Thompson, Jr.

Samuel C. Thompson, Jr.

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

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

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

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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