February 8, 2022
Inverted Debt Restructurings: A Mind-Numbing Maze
Featured in Tax Notes, January 2022
This year, President Biden and members of Congress released tax proposals to increase the U.S. Corporate tax rate, as well as the U.S. effective rate on foreign earnings. In today's environment, companies engaging in a restructuring should also consider whether it is beneficial to invert. A&M's Lee G. Zimet shares with Tax Notes the nuances of section 7874 anti-inversion rules and the complications generally overlooked in debt restructuring.
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