The benefits and pitfalls of participating in a corporate inversion: a case study of two companies on two different paths

Even though the term corporate inversion has been heard globally for decades, it has only become more prevalent in the United States during the past two years. This case study examines two United States companies that recently had very high profile and public corporate inversion experiences. Complicated tax laws and high tax rales have long eroded the ability of United States companies to remain competitive on a global scale. During the past two years, tax reform has been elevated to the Presidential and Congressional levei. Because these reform efforts have stalled, however, and in the constant search for ways to become more competitive and profitable, United States dorniciled companies have begun to more aggressively explore corporate inversion. This case study of Walgreens Alliance Boots and Mylan N.V., is undertaken because while the reasons to pursue a corporate inversion for both companies were very similar and done during the same time period, the internai process and final outcome were dramatically different. The other dynamic studied is the role both internai and externai politics had on these two cornpanies and how they influenced the decisions made by the executives. Lastly, the Obama Administration continues to threaten so called "corporate America" to remain in the country through regulatory pressure, but this has not stopped companies frorn pursing corporate inversions. Legislatively, attempts at corporate tax reform, another way to encourage Untied States companies to remain, have also failed. I will not try to determine i f a corporate inversion is the right path for a company to take. I am examining how the rise o f the practice o f corporate inversions has been elevated in boardroorns, on Wall Street, in Congress and at the White House during the past two years.

Fiscal Panorama of Latin America and the Caribbean 2013: tax reform and renewal of the fiscal covenant

Includes bibliography

Tax policy in Latin America: Assessment and guidelines for a second generation of reforms

Includes bibliography

Effetti dell’introduzione dei Principi contabili internazionali sul principio di derivazione del reddito d’impresa dal risultato di bilancio

Con il presente lavoro si è tentato di verificare se le ragioni che hanno portato l’ordinamento italiano ad adottare il principio della derivazione del reddito d'impresa dal risultato contabile, possano essere considerate ancora attuali alla luce dell'introduzione dei principi IAS/IFRS nel nostro sistema contabile. In particolare, si è cercato di esaminare se questo collegamento ai principi contabili internazionali, introdotto nel nostro ordinamento anche per la redazione dei bilanci d'esercizio, abbia comportato il venir meno della neutralità dell'imposizione fiscale tra le società cd. Ias adopter e no Ias adopter. L'analisi di questa problematica è stata condotta anche prendendo come riferimento le modalità di recepimento delle opzioni contenute nel Regolamento n. 1606/2002 da parte dei legislatori di alcuni Stati europei, e valutando se le conseguenze fiscali emergenti tra i vari ordinamenti possano creare possibili distorsioni alla concorrenza ed alle libertà fondamentali dell’Unione europea.

Thin Capitalization Rules and Entrepreneurial Capital Structure Decisions

Tax planners often choose debt over equity financing. As this has led to increased corporate debt financing, many countries have introduced thin capitalization rules to secure their tax revenues. In a general capital structure model we analyze if thin capitalization rules affect dividend and financing decisions, and whether they can partially explain why corporations receive both debt and equity capital. We model the Belgian, German and Italian rules as examples. We find that the so-called Miller equilibrium and definite financing effects depend significantly on the underlying tax system. Further, our results are useful for the treasury to decide what thin capitalization type to implement.

An analysis of the revenue policy -making process of the Texas Legislature

The purpose of this dissertation was to develop a conceptual framework which can be used to account for policy decisions made by the House Ways and Means Committee (HW&MC) of the Texas House of Representatives. This analysis will examine the actions of the committee over a ten-year period with the goal of explaining and predicting the success of failure of certain efforts to raise revenue.^ The basis framework for modelling the revenue decision-making process includes three major components--the decision alternatives, the external factors and two competing contingency theories. The decision alternatives encompass the particular options available to increase tax revenue. The options were classified as non-innovative or innovative. The non-innovative options included the sales, franchise, property and severance taxes. The innovative options were principally the personal and corporate income taxes.^ The external factors included political and economic constraints that affected the actions of the HW&MC. Several key political constraints on committee decision-making were addressed--including public attitudes, interest groups, political party strength and tradition and precedents. The economic constraints that affected revenue decisions included court mandates, federal mandates and the fiscal condition of the nation and the state.^ The third component of the revenue decision-making framework included two alternative contingency theories. The first alternative theory postulated that the committee structure, including the individual member roles and the overall committee style, resulted in distinctive revenue decisions. This theory will be favored if evidence points to the committee acting autonomously with less concern for the policies of the Speaker of the House. The Speaker assignment theory, postulated that the assignment of committee members shaped or changed the course of committee decision-making. This theory will be favored if there was evidence that the committee was strictly a vehicle for the Speaker to institute his preferred tax policies.^ The ultimate goal of this analysis is to develop an explanation for legislative decision-making about tax policy. This explanation will be based on the linkages across various tax options, political and economic constraints, member roles and committee style and the patterns of committee assignment. ^

Efficient taxation of multi-national enterprises in the European Union. Bruges European Economic Policy (BEEP) Briefing 5/2003

Current arrangements for multi-national company taxation in EU are plagued by severe conceptual and administrative problems, leading to high compliance costs, considerable uncertainty and ample room for abuse. Integration is amplifying these difficulties. There are two possible approaches in designing an efficient trans-border corporate tax system for the European Union. The first is to consolidate the EU-wide operations of MNEs, using an agreed common base as the reference variable, and then to apportion this total tax base using some presumptive indicators of activity in each tax jurisdiction – hence, implicitly, of the likely benefits stemming from each location. The apportionment formula should respect requisites of neutrality between productive factors and forms of corporate financing. A radically different approach is also available that offers considerable advantages in terms of efficiency, simplicity and decentralisation, including full administrative autonomy of national tax authorities. It entails abandoning corporate income as the relevant tax base and taxing at a moderate rate some agreed measure of business activity such as company value added, sales or employment. These are the variables usually considered in formula apportionment, but they would apply directly without having first to go through the complications of EU-wide consolidation based on a common-base definition. Reference to a broad base, with no exemptions or deductions, would allow to set low statutory rates.

Tax reform for fairness, simplicity, and economic growth : the Treasury Department report to the President.

Item 925

Statistics of income.

Later information in the Service's publications on specific types of returns.

1976 statistics of income, supplemental report : individual retirement arrangements /

Prepared by Nick Greenia and Dan Rosa.

Statistics of income.

Vol. for 1916 issued as House document 1169, 65th Cong., 2d sess.; 1951, pt. 1, 1952-53 issued as the Service's IRS publication (varies slightly) (Law)

Statistics of income and related administrative record research : 1988-1989 /

"December 1990."

Federal tax accounting.

Earlier editions have title: Income tax accounting.

Tax reform act of 1976, H.R. 10612 : testimony to be received ... /

At head of title: 94th Congress, 2d session. Committee print.

A Preliminary review of the impact of the tentative federal tax reform compromise /

Cover title.