Analysis of corporate inversion

Several prominent public corporations have recently embraced a noteworthy (and newsworthy) type of transaction known as a “tax inversion.” In a typical inversion, a US multinational corporation (MNC) merges with an operating foreign company. The entity that ultimately emerges from this transactional cocoon is invariably incorporated abroad, yet typically remains listed in domestic securities markets (under the erstwhile US issuer’s name). When structured to satisfy applicable tax requirements, corporate inversions permit domestic MNCs eventually to replace US tax treatment with foreign tax treatment of their extraterritorial earnings – almost always at far lower effective rates (sometimes even zero). Most regulators and politicians have reacted to the inversion invasion with alarm and indignation, no doubt fearing that the trend is but a harbinger of an immense offshore exodus by US multinationals.