Five Changes to U.S. Tax Law that Reduce the Benefits of Corporate Inversion Transactions White Paper

Five Changes to U.S. Tax Law that Reduce the Benefits of Corporate Inversion Transactions White Paper

In 2014, Congress made another attempt to halt the surge in corporate inversions with the introduction of the Stop Corporate Inversions Act of 2014 (H.R. 4679, S. 2360). This bill sought to amend the Internal Revenue Code to revise rules for the taxation of inverted corporations to provide that a foreign corporation that acquires the properties of a U.S. corporation will be subject to U.S. taxation if they pass one of two tests after the transaction is completed: (1) It holds more than 50% of the stock of the new entity; or (2) The management or control of the new entity occurs primarily within the U.S. and the new entity has significant domestic business activities. The bill was referred to the House Ways and Means Committee and the legislation was re-introduced in 2015 (H.R. 415, S. 198).

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