Corporate Inversions: New challenges, New Opportunities

With a wave of recent tax inversion and corporate reorganization discussions, corporate tax strategy has begun to move to the forefront of media, public and Congressional attention. These high-profile inversion strategies have gained momentum and achieved heightened attention, becoming a matter of public policy matter in 2014. While corporate international tax strategies have existed since the dawn of the U.S. federal income tax, inversions in their current form have been active only since the 1980s. Using three predominate inversion cases as a lens, this research intends to fill a gap in the existing literature relating to corporate inversions. By combining existing case law, tax legislation, and Treasury regulations, this paper develops a framework for supporting strategic global tax initiatives. The conclusions and recommendations reached are generalizable and appropriate for use in developing best practice solutions