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 2026

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 With foreign profits trapped offshore by an outdated, worldwide system which would hit them with a tax on repatriation, as well as a high tax rate, the temptation to consider an inversion is proving too much for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

Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
Gift this article