In late September, the U.S. Treasury Department proposed new regulations to help curb corporate inversions—the merging of a U.S.-based company with a foreign company so that the foreign company becomes the parent of the combined operations, resulting in significant tax benefits.
Inversions have captured headlines and mindshare since late August, when Burger King Worldwide merged with the Canadian chain Tim Hortons. Once joined, the company will be the world’s largest quick service restaurant company. The firm will also be headquartered in Canada, which has a lower tax rate than the U.S. While Burger King’s expected inversion brought the issue into the general consciousness, many other companies have similar stories. According to Reuters, 76 U.S. corporations have completed inversions since 1983; 47 of those deals have occurred since 2004. Some of these companies are obscure, others well known. The name brands that have essentially relocated as a result of inversions include Fruit of the Loom, Seagate Technology, Accenture, PricewaterhouseCoopers Consulting, Herbalife International, Tyco Electronics, Covidien, and Medtronic
MIT Sloan Professor of Accounting Michelle Hanlon recently surveyed 600 tax executives to better understand the impact of U.S. tax policy on corporate decisions about investment location and profit repatriation. Hanlon’s research showed that both the tax and financial accounting effects lead to greater foreign direct investment by U.S. companies and lower repatriation [of taxable funds.]