Revisiting the Law of Moses' Rod: The Case of Inversions
8 Pages Posted: 12 Nov 2014
Date Written: November 11, 2014
This article revisits Marty Ginsburg’s "Law of Moses’ Rod in the Context of Inversions", in particular how proposed revisions to the anti-inversion rules could be used to justify new, or even more aggressive, expatriation strategies. While not advocating that any taxpayer or other party pursue specific strategies or that they are "good" from a tax policy standpoint, the goal in examining potential inversion strategies even in the face of anti-inversion rules is to help find ways to incorporate anti-abuse provisions into the larger structural goals of the income tax.
Keywords: inversions, international tax,
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