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Tax inversion

A tax inversion or corporate tax inversion is a form of tax avoidance where a corporation restructures so that the current parent is replaced by a foreign parent, and the original parent company becomes a subsidiary of the foreign parent, thus moving its tax residence to the foreign country. Executives and operational headquarters can stay in the original country. The US definition requires that the original shareholders remain a majority control of the post-inverted company. In US federal legislation a company which has been restructured in this manner is referred to as an inverted domestic corporation, and the term "corporate expatriate" is also used, for example in the Homeland Security Act of 2002.

Concept
While the legal steps taken to execute a tax inversion can be complex as the corporations need to avoid both regulatory and Internal Revenue Service (IRS) hurdles in re-locating their tax residence to a lower-tax jurisdiction, simplified examples are available; such as provided in August 2014, by Bloomberg journalist Matt Levine when reporting on the Burger King tax inversion to Canada. Before the 2017 TCJA, U.S. companies paid a corporate tax rate of 35% on all income they earned in both the U.S., and abroad, but they obtained a credit against their U.S. tax liability for the amount of any foreign tax paid. Given that the U.S. tax rate of 35% was one of the highest in the world, the corporate's maximum global tax liability should, therefore, have been 35%. This pre-TCJA U.S. tax system, was referred to as a "worldwide tax system", as opposed to the "territorial tax system" used by almost all other developed countries. Levine explained:If we're incorporated in the U.S., we'll pay 35 percent taxes on our income in the U.S. and Canada and Mexico and Ireland and Bermuda and the Cayman Islands, but if we're incorporated in Canada [who operate a "territorial tax system"], we'll pay 35 percent on our income in the U.S. but 15 percent in Canada and 30 percent in Mexico and 12.5 percent in Ireland and zero percent in Bermuda and zero percent in the Cayman Islands.By changing its headquarters to another country with a territorial tax regime, the corporation typically pays taxes on its earnings in each of those countries at the specific rates of each country. In addition, the corporation executing the tax inversion may find additional tax avoidance strategies, called tools, that can shift untaxed profits from the higher-tax locations (e.g. the U.S.), to the new lower-tax country to which the corporation has now inverted. ==History==
History
The following are notable events in the history of US and non-US corporate tax inversions: US experience • 1983: The first officially recognized US corporate tax inversion was of McDermott International from Texas to Panama. Academics refer to it as a first-generation inversion. • 1990: The relocation of Flextronics from California to Singapore; however, it is not considered as a full tax inversion. • 1994: The second officially recognized US corporate tax inversion was of Helen of Troy Limited from Texas to Bermuda. • 1996–2004: The first major wave of US tax inversions mainly to Caribbean tax havens such as Bermuda and Cayman Islands; these inversions were mostly "naked inversions" where the corporate re-domiciled to a tax haven in which they had no existing business, and included: Ingersoll-Rand, Accenture, Seagate, Cooper, and Tyco. Academics refer to them as third-generation inversions. such as Ireland (Ingersoll-Rand, Accenture, Seagate, Cooper, and Tyco), and Switzerland (Weatherford and Noble), fearing a backlash from a new Democratic administration. • 2014: The value of new proposed US tax inversions in 2014 alone (US$319 billion) exceeds the cumulative value of all previous US tax inversions in history. • 2014: The US Treasury further tightens the regulations around the existing AJCA/TD 9592 thresholds; AbbVie cancels a US$54 billion inversion to Ireland with Shire plc. AbbVie announced that post the 2017 TCJA, its effective tax rate was already lower than that of Irish-based Allergan plc at 9%, and that post the acquisition, it would rise to 13%. UK experience • 2007–2010: The United Kingdom loses a wave of tax inversions mainly to Ireland including: Experian plc, WPP plc, United Business Media plc, Henderson Group plc, Shire plc, and Charter. • 2013: Liberty Global completes the second largest US tax inversion in history in a US$24 billion merger with Virgin Media in the UK. • 2016: The UK becomes the third most popular destination in history for US tax inversions with 11 inversions (Ireland is top with 21 inversions). • 2018: The Japanese Takeda Pharmaceutical Company announced that it was merging with Irish-based Shire plc (a previous UK inversion to Ireland in 2008); however, after some initial confusion, Takeda clarified that it was not executing an inversion to Ireland and that its legal headquarters would remain in Japan. ==Drivers==
Drivers
Reduced taxes ) While corporates who execute inversions downplay taxation in their rationale for the transaction, and instead emphasise strategic rationale, research is unanimous that tax was the driver for most US tax inversions from 1983 to 2016. Types of tax saving US research on US tax inversions breaks down the tax savings into three areas: • Tax on US income. Before the 2017 TCJA, the US corporate tax rate was one of the highest rates in the developed world at 35%. The US was one of only eight jurisdictions using a "worldwide tax system". All other jurisdictions used a "territorial tax system" where very low rates of taxation are applied to foreign-sourced profits (e.g. in Germany was at 5%). US tax academics noted this was the reason why non-US corporations made limited use of tax havens; BEPS tools such as the "Double Irish", Ensuring that such reserves would be protected from any initiatives by Congress to subject them to US taxes required an inversion to another jurisdiction. Medtronic's US$20 billion in untaxed offshore reserves was noted as a driver for their 2015 inversion. • After year one, the aggregate effective rate of worldwide taxation of the inverted company fell from a 29% rate to an 18% rate; and • By year three, the aggregate worldwide tax expense was 34% lower, while the US tax expense was 64% lower. A 2014 report by the Financial Times on US pharmaceutical tax inversions during 2012–2014, showed their aggregate worldwide tax rates dropped from 26 to 28% to 16–21%. Shareholder impact A number of studies have shown that the after-tax returns to original company shareholders post-inversion are more mixed, and often poor: • A 2014 report by Reuters on 52 completed US tax inversions since 1983 showed that 19 outperformed the S&P500, another 19 underperformed the S&P500, another 10 were bought by rivals, another 3 went bankrupt and the final one returned to the US. Reuters concluded that: "But the analysis makes one thing clear: inversions, on their own, despite largely providing the tax savings that companies seek, are no guarantee of superior returns for investors". • A 2017 study published in the Journal of Financial Economics, found that while inversions lowered the corporate tax and increased the economic value of the corporate, the after-tax benefits to shareholders were distributed disproportionately. CEOs and short-term shareholders, foreign shareholders, and tax-exempt shareholders benefitted disproportionately from inversions. However, long-term domestic shareholders did not benefit from inversions, since the US tax code requires taxable shareholders to recognize their capital gains at the time of the inversion. • A 2019 study published in the International Review of Financial Analysis, found in the short-term, shares of inverting corporates increased in value. In the medium to longer-term, however, they found that the share price tended to decline. The driver was shown to be partly agency costs, and a distinction was drawn between the material gains of the CEO from the inversion and the losses of long-term shareholders. There were concerns on the acquisition premiums paid in inversion mergers, and that inversions tended to be favoured by corporates with poor growth outlooks. ==Types==
Types
Definition , United States In 2017, the US Congressional Budget Office (CBO) stated that it only considered a transaction to be a tax inversion under the following conditions: For example, the executives of Medtronic, who executed the largest tax inversion in history by legally moving Medtronic to Ireland in 2015, remained in their main operational headquarters of Fridley, Minnesota in the US. All of Medtronic's substantive business and management operations still reside in the US. Sometimes, the 2015 US$70 billion merger of Allergan plc and Activis plc, both previous US tax inversions to Ireland, are listed as a tax inversion (and the largest executed inversion in history). However, as both companies were legally Irish companies, their merger was not considered a tax inversion. • Substantial business presence. A US corporation creates a new foreign subsidiary, and exchanges each other's equity in proportion to their valuations so that after the exchange, the new entity is a foreign corporation with a US subsidiary. There is no "change of control". This is also called a "naked tax inversion", a "shell inversion", a "self-help inversion", or "redomiciling". • A smaller foreign corporation acquired by a larger US corporation. A US corporation merges with a smaller foreign corporation who becomes the new legal parent of the group. The existing US shareholders still own a majority merged group this thus maintain "effective control", however, it is now a foreign company under the US tax code. In 2018, academics identified a new class of tax inversion as details of Apple's Q1 2015 leprechaun economics transaction in Ireland emerged. While Apple's tax residence remained in the US, Apple moved the legal tax residence of a large part of its business to Ireland in a US$300 billion quasi-tax inversion of its intellectual property (IP). For example, the CAIA BEPS tool Apple used in 2015 would give Apple an "effective tax rate" of under 2.5% on the worldwide profits Apple generated on this IP that was shifted to Ireland. posted that Ireland could see a "boom" in the onshoring of U.S. IP, via the CAIA BEPS tool, between now and 2020, when the Double Irish is fully closed. In February 2019, Brad Setser from the Council on Foreign Relations, wrote a New York Times article highlighting issues with TCJA in terms of combatting power of BEPS tools. ==Industries==
Industries
In 2017, the Congressional Budget Office reported that of the 60 US tax inversions from 1983 to 2015 which the CBO officially recognize, over 40% came from three industries: Pharmaceutical preparations (9), Fire, marine, and casualty insurance (7), and Oil & Gas Well Drilling and Servicing (7). The US Oil & Gas Well Drilling and Servicing and US Casualty Insurance inversions are mostly associated with the first wave of US tax inversions before 2004; In August 2016, after the US Treasury blocked Pfizer's US$160 billion tax inversion to Ireland with Allergan, Bloomberg stated that "Big Pharma Murdered Tax Inversions". ==Earnings stripping ==
Earnings stripping {{anchor|Tools}}{{anchor|Earnings stripping}}
An important concept in inversions are the tools required to shift untaxed profits from the corporate's existing operating jurisdictions to the new destination. This is known as earnings stripping. Without these tools, a tax inversion might not deliver the expected tax savings, as the profits might arrive at the new destination having incurred full taxes in the jurisdictions in which they were sourced. Medtronic and Allergan, therefore, could only avail of Ireland's lower effective tax rates if they could shift US-sourced profits to Ireland without incurring full US corporate taxes. Studies have shown that the earnings stripping of US-sourced earnings is a critical component of reducing the aggregate effective tax rate post the inversion (per ). The two main types of tools used in tax inversions are: • Debt-based tools. This is where the foreign parent of the newly inverted company raises debt to acquire the original US company. This debt is then "moved down" into the US subsidiary and the US profits are thus shifted untaxed to the foreign patent via interest payments on this debt. Early US tax inversions involved highly leveraged structures with real external debt. created in the 2017 TCJA, directly targeted debt-based tools via the new BEAT tax, and introduce a competing US IP-based BEPS tool called the FDII tax. ==Costs==
Costs
There have been several estimates of the aggregate cost of US tax inversions to the US exchequer (also called the erosion of the US tax base). However, there is a significant variation in these aggregate estimates of tax erosion over the years due to two specific factors: • Variation in US inversions. Firstly, there has been material variation in the financial scale of inversions since 1983. In 2014, a Joint Committee on Taxation (JCT), estimated that stopping inversions would prevent US$19.5 billion in lost taxes over the next decade (2015–2024), or US$1.95 billion annually on average. At the time, this figure was just 0.4% of the estimated total US corporate taxation revenues for the next decade, of US$4.5 trillion (2015–2024). However, just three years later, the scale of US tax inversions had increased dramatically, leading the CBO to re-forecast in 2017 that by 2027, annual US taxes would be circa 2.5% (or US$12 billion) lower due to tax inversions. • Effect of hybrid inversions. Secondly, estimates can vary dramatically depending on whether the effect of hybrid inversions is included. The CBO (and other US State estimates above) ignore hybrid inversions. In 2016, tax academic Kimberly Clausing estimated that the loss to the US exchequer from all classes of inversions, using the broadest types of hybrid inversions (and all base erosion and profit shifting earnings stripping activity), by US corporations was between US$77 to US$111 billion in 2012 (having been zero 20 years ago). ==Destinations==
Destinations
US inversions (2015). The US Congressional Budget Office and the Congressional Research Service have cataloged 85 US tax inversions since 1983 to 2017 (the CBO does not recognize all of them as official tax inversions). Bloomberg used this data to identify the most attractive destinations for US inversions titled Tracking the Tax Runaways which won the 2015 Pulitzer Prize for Explanatory Reporting, and was updated to 2018. While the full list is not available, the US Tax Foundation listed the nine most important UK inversions of which six went to Ireland (Experian plc, WPP plc, United Business Media plc, Henderson Group plc, Shire plc, and Charter International), and one each went to Switzerland (Informa), Luxembourg (Regus), and the Netherlands (Brit Insurance). Other jurisdictions Few other jurisdictions outside of the US and the UK have experienced a material outflow of corporate tax inversions to other destinations. ==Countermeasures==
Countermeasures
United States There have been three phases of initiatives that the US Government have taken to counter US corporate tax inversions: • 2004 American Jobs Creation Act (ACJA): :In 2002, the US Treasury reported to Congress that there had been a "marked increase in the frequency, size, and visibility" of "naked inversions". The Treasury cited three concerns: the erosion of the US tax base, a cost advantage for foreign-controlled firms, and a reduction in perceived fairness of the tax system. In response, Congress passed the AJCA, which added Section 7876 to the US tax-code that effectively ended "naked inversions" to Caribbean-type tax havens where the US corporation had no previous business presence in the location. The main provisions were: :* Where the existing US shareholders owned between 60% but less than 80% of the EAG, the inversion would be recognized as a foreign company but with restricted tax benefits. • In 2012, the Treasury issued regulation T.D. 9592 that increased the threshold for the "substantive business presence" safe harbour exemption from Section 7876, from 10% to 25%. : While the 2004 ACJA and the 2012–2016 Treasury Regulations sought to block US corporate tax inversions, the TCJA attempted to remove the taxation incentives by reforming elements of the US tax code. Such a reform had been completed by the UK in 2009–2012 (see below). The main provisions were: In March 2018, the Head of Life Sciences in Goldman Sachs made the following comment: Federal procurement regulations require corporations bidding for government contracts to affirm that they are not inverted domestic corporations and require contractors who do become inverted domestic corporations to notify their Contracting Officer within five business days of the change of their status. In a report to Congress in March 2019, the Congressional Research Service noted that "there are also indications that most tax motivated inversions had already been discouraged by the 2016 regulations" and that since the 2017 TCJA that "Some firms appear to be considering reversing their headquarters [or past inversion] decision". In June 2019, U.S.-based AbbVie announced an agreement to acquire Irish-based Allergan plc for US$63 billion; however, the acquisition would not be structured as a tax inversion, and that the Group would be domiciled in the U.S. for tax purposes. In a 2015 presentation, the UK HMRC showed that many of the outstanding UK inversions from 2007 to 2010 period had returned to the UK as a result of the tax reforms (most of the rest had entered into subsequent transactions and could not return, including Shire). ==Notable inversions==
Notable inversions
US inversions Executed • 1982: McDermott International to Panama; the first ever tax inversion, first ever "naked inversion", and the only ever US tax inversion to Panama. • 1998: Fruit of the Loom to the Cayman Islands. Entered into bankruptcy three years later and was then bought by Berkshire Hathaway. • 1999: Transocean to the Cayman Islands. • 2001: Ingersoll Rand to Bermuda. "Self-inverted" to Ireland in 2009. • 2003: Capri Holdings/Michael Kors to the British Virgin Islands; the only ever US inversion to the BVI. Later self-inverted to the UK. • 2009: Valaris to the United Kingdom; the first US inversion to the UK. • 2012: Eaton Corporation to Ireland in a $US12 billion merger with Cooper Industries; fourth-largest inversion in history. • 2014: Walgreens to the United Kingdom, after already having merged with US$16 billion UK-based Alliance Boots. Walgreens decided to maintain its legal headquarters in the US. • 2014: Pfizer to the United Kingdom in a US$120 billion merger with AstraZeneca; would have been the largest inversion in history, but the latter rejected Pfizer's offer of GBP£55 per share. • 2016: Pfizer to Ireland in a US$160 billion merger with Allergan; would have been the largest inversion in history, but was blocked by the US Treasury. ==See also==
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