Layla Asali Comments on Corporate Inversions in Tax Notes Today

"Treasury Saw Exception to Inversion Regs' Disqualified Stock Rule as Slippery Slope"
Tax Notes Today
03.14.14Layla Asali commented on the Obama administration's fiscal 2015 budget proposal, which seeks to institute a new U.S. business activities and management test to further discourage inversions. The new proposal provides that if a foreign corporation acquires a domestic corporation and, following the acquisition, the foreign corporation's group has substantial business activities in the United States and is managed and controlled in the United States, the foreign corporation could be treated as a domestic corporation for U.S. federal income tax purposes. A Treasury official said it wouldn't be easy for companies to violate the proposed rule, since substantial business activities would be a "high hurdle" to cross. Asali disagreed. "It's not as high of a hurdle when you are talking about the United States," she said. "It's a huge market."
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