Tax Inversion
ISSUE
The client would like to complete a tax inversion by acquiring a foreign company in
Switzerland and moving the domicile of the combined company overseas in order to
significantly reduce the company’s corporate income tax burden and seeks our
recommendation.
FACTS
– The client is a US corporation subject to income tax in the US at a 21% rate
– The client is seeking to acquire a Swiss-domiciled company
– The client believes the Swiss corporate income tax rate is 5%
–
IDENTIFY SOURCES
(although this is generally not included in a good form tax research
memorandum, it is included as required in the grading rubric for the assignment)
In order to identify the primary sources of tax law related to tax inversions, I conducted a search in Checkpoint querying “Inversions”. Based on that search I identified the relevant IRC section related to inversions is IRC Section 7874. I also identified secondary sources that help me better understand the implications of IRC Section 7874.
Corporate Expatriation, Inversions and Mergers: Tax Issues (Updated March 12, 2019, Congressional Research Service R43568, Retrieved from:
https://crsreports.congress.gov
Checkpoint Catalyst Library International (U.S. Income Tax), 2112 Inversions.

DETAILED ASSIGNMENT

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