Inversions - special focus

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Inversions - special focus

inversions-c.png

Between 1983 and 2004 there were 29 inversion transactions out of the US. In the decade following, almost 50 companies restructured using the method. With foreign profits trapped offshore by an outdated, worldwide system which would hit them with a tax on repatriation, as well as a high tax rate, the temptation to consider an inversion is proving too much for US companies, particularly those in the highly-mobile pharmaceuticals sector. Whatever the motivation, inversions are in vogue. ITR’s special report looks at the knock-on impacts of the current wave of inversions, including shareholder pressure to consider an option they see their rivals pursuing and the possible inflammation of the tax morality debate in the US. We also bring you exclusive insight as to why Danaher is not looking to invert.

Download the special report as a PDF

The past month has seen a growing number of US politicians and legislators crying foul at the practice of inverting. President Obama has described inverters as “fleeing the country to get out of paying taxes”, while Jacob Lew, US Treasury Secretary, has called for a greater sense of “economic patriotism”. Democrats are more adamant about curbing the restructuring technique immediately, while Republicans, for the most part, want to see action under the umbrella of comprehensive tax reform. Sander Levin, his brother Carl, and Ron Wyden, Senate Finance Committee chairman, are among those to have proposed specific anti-inversion legislation, including legislation that would have retrospective effect to May 8 2014. Efforts to reform the US tax code indicate the crawling pace of change on Capitol Hill, but there is no denying there is a narrowing window of opportunity for taxpayers already looking at restructuring, or considering a merger or acquisition, to think about inverting.

Check out our infographic on page 5 to see how pharmaceuticals companies are leading the inversions charge, and review our insights as to which company in the sector could be next to invert.

Engage in the debate on social media: you can join our Facebook or LinkedIn group to share insights with fellow professionals, or tweet @Intltaxreview using #inversionsITR

Twitter

Tweet this         

Twitter
#inversionsITR         
LinkedIn
LinkedIn group

Contents

inv1.png

Inversions trend continues to cause controversy

July 18 2014

inv2.png

Companies under pressure to consider inverting

July 4 2014

inv3.png

Why Danaher Corporation is not looking to invert

July 18 2014

Download this special report as a PDF

Further reading

more across site & shared bottom lb ros

More from across our site

An OECD report has uncovered a lack of public trust in politicians as a source for tax information. Banning them from owning shares in companies could boost confidence
‘We did not expect to carve out big economies from the minimum tax system’, Estonia’s finance minister said; in other news, Blick Rothenberg has acquired The Vat Consultancy
The proposal seeks to regulate compulsory TP documentation in line with the OECD Transfer Pricing Guidelines and simplify filing requirements
Despite the decline in profitability, the firm’s tax advisory business delivered a 3.4% revenue growth
Firms are making use of inventories and ample profit margins to avoid or absorb the initial impact of higher tariffs, an OECD report said
While UN proposals to shift airline taxation from a residence-based system to a source-state one are not set in stone, ex-British Airways CEO Willie Walsh warns they would increase costs and complexity
Von Wobeser y Sierra’s head of tax shares best practices for resolving tax controversy and touts his firm’s founding partner as an exemplar of legal practice
ITR concludes its analysis of World Tax’s rankings for 2026 by highlighting the firms that stood out most on a global scale
Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage
They also warned against an ‘unnecessary duplication of efforts’ in UN tax convention negotiations; in other news, White & Case has hired Freshfields’ former French tax head
Gift this article