The Resource Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada

Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada

Label
Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada
Title
Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada
Creator
Subject
Language
eng
Summary
In 2004, Congress enacted par. 7874 to put an end to certain perceived abuses associated with "inversion transactions", i.e., transactions in which a US-based multinational corporation migrates to a lower-tax jurisdiction in order to reduce US taxation. It is possible that a foreign multinational public company's acquisition of a US business could potentially be subject to par. 7874, not because such acquisition would be done to avoid US tax or because the foreign country in which the foreign public company is organized is a low-tax, abusive jurisdiction, but rather because the 2012 Temporary Regulations' high threshold, inflexibility, and unreasonable definitions and exclusions could prevent the foreign public company from being considered engaged in substantial business activities in its country of organization. This article provides an overview of the 2012 Temporary Regulations and calls attention to some problems with their application, as highlighted by the potential issues that could arise in the context of an acquisition of a US business by certain Canadian public corporations
Citation source
In: Tax management international journal. - Arlington. - Vol. 41 (2012),
http://library.link/vocab/creatorName
  • Glicklich, P.A
  • Leitner, A
  • Grandinetti, M.J
Language note
English
http://library.link/vocab/subjectName
  • inversion transaction
  • MNE
Label
Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada
Instantiates
Publication
Label
Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada
Publication

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