Why Corporate Inversions are Irrelevant to U.S. Tax Policy

6 Pages Posted: 3 Jan 2016 Last revised: 11 Feb 2016

Date Written: March 9, 2015


Bogenschneider argues that inversions result primarily from shareholders’ inability to replace ineffective corporate management under Delaware corporate law. He contends that the new theory of capital ownership neutrality is based on the counterfactual assumption of fixed capital investments by U.S. multinationals, and not marginal capital investment by a growing company, which is already tax deductible. Bogenschneider also observes that U.S. multinationals typically operate with effective tax rates equal to or less than those of foreign multinationals.

Keywords: corporate inversion

Suggested Citation

Bogenschneider, Bret, Why Corporate Inversions are Irrelevant to U.S. Tax Policy (March 9, 2015). 146 Tax Notes1267 (March 9, 2015). Available at SSRN: https://ssrn.com/abstract=2709000

Bret Bogenschneider (Contact Author)

University of Surrey - School of Law ( email )

United Kingdom

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