Corporate Inversions: Evolutionary Process And Key Policy Considerations

Abstract

The Article brings a tax issue of utmost importance to the foreground. Why corporate inversions occurred in the U.S. in the last decades? How did the U.S. tax system respond to this phenomenon? And most importantly, how the history of inversions informs the current debates on the regulation of inversion transactions?

The Article traces the history of inversions in the U.S. in the past decades to highlight some of the critical lessons they provide. It also deals with the U.S. tax system’s response to this tax planning technique as reflected by the development of the anti-inversion rules which attempted to curb such
phenomenon.

The Article puts forward that policy discussions on inversions should inform themselves with the history of this phenomenon and reasons that accounted for the U.S. MNEs’ decisions to expatriate over the last decades.

Keywords: Inversions, Corporate Inversions, TCJA, International Taxation, Tax Policy

JEL Classification: H26