Inversion Delusion
On Monday, the Tax Policy Center in Washington held a panel discussion on the subject of “corporate inversions” — the practice of taking over a small company in someplace like Ireland or the Netherlands, and then using that takeover to “relocate” to the foreign country for tax reasons. One of the panelists was John Samuels, the chief tax lawyer for General Electric.
Samuels started by saying that even the most junior tax lawyers know that, when structuring a cross-border merger, “you should do whatever you can, whatever’s possible, to make sure the ultimate parent or acquirer is a foreign company, not a U.S. company, to avoid having the entire worldwide income caught up in the U.S. tax net.” He went on: “Virtually every major developed country in the world has dramatically reformed its tax system to make it more business-friendly.” He cited Britain as an example. “The U.K. recently abandoned its worldwide system for a territorial system [and] reduced its corporate tax rate to 21 percent.” Quoting the exchequer secretary to the Treasury, he added, Britain “wants to send out the signal loud and clear that Britain is open for business.”
The corporate tax rate in the United States is 35 percent, which is the highest in the industrialized world. And, unlike most other countries, it taxes a company’s worldwide earnings, at that same high rate, once they are repatriated into the United States. (That is what Samuels meant by a “worldwide system.”)
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But upon closer inspection, this argument turns out to be mainly hogwash. As Edward D. Kleinbard put it in a recent report, “ ‘Competitiveness’ has nothing to do with it.”
http://www.nytimes.com/2014/09/09/opinion/joe-nocera-inversion-delusion.html?emc=edit_th_20140909&nl=todaysheadlines&nlid=38945174
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