|
Tax inversion, or corporate inversion, is a largely American term for the relocation of a corporation's legal domicile to a lower-tax nation, or corporate haven, usually while retaining its material operations in its higher-tax country of origin.〔(Corporate Inversion )〕〔Subcommittee on Select Revenue Measures of the House Committee on Ways and Means (June 25, 2002). (Statement of the Hon. Richard Blumenthal, Attorney General, Connecticut Attorney General's Office, Hearing on Corporate Inversions ). Retrieved September 5, 2004.〕 The first inversion in the U.S. took place in 1982, but the practice became common only in the late 1990s, with US corporations seeking to relocate to tax havens such as Bermuda.〔"Twenty years ago inversions were rare. But as other countries chopped their rates and America’s stayed the same, the incentive to flee grew. Until a decade ago Bermuda and other tax havens were the destination of choice". 〕 More recently, because of changes in US law, a second wave of corporate inversions took place by way of merger with companies in lower-tax foreign countries such as Ireland. The issue drew public attention in 2014 when Pfizer proposed to invert to the U.K. through a takeover of AstraZeneca. Tax inversions are a form of tax avoidance, whereby corporations and individuals arrange their affairs to legally reduce their tax obligations. Unlike that of most other developed nations, the U.S. tax code imposes income tax on the profits of American corporations' foreign subsidiaries.〔"America levies tax on a company’s income no matter where in the world it is earned. In contrast, every other large rich country taxes only income earned within its borders." 〕 This creates a strong incentive for American companies with large overseas markets to seek to recharacterize themselves as a foreign corporation. Inversion transactions usually involve the transfer of stock of a corporation by one or more shareholders to a wholly or partly owned subsidiary of that corporation in exchange for newly issued shares of the subsidiary's stock. I.R.C. § 7874 (Rules relating to expatriated entities and their foreign parents) contains the tax rules related to inversions. ==Recent publicity== Tax inversions as a tax reduction maneuver became a public policy issue in 2014 because of a series of high-profile inversion proposals. While both Democrats and Republicans have called for reforms of the tax code to eliminate the underlying incentives to invert, they split over whether to enact short-term measures to discourage inversions in the meantime. Legislation proposed by Congressional Democrats that would prevent some merger-driven inversions was blocked by Republicans. President Barack Obama called the maneuvers "unpatriotic" during a speech in July 2014, and Treasury Secretary Jack Lew issued regulations in September 2014 meant to crimp some of the tax advantages of the transactions.〔(Corporate Inversions )〕〔(Corporate inversion transactions: Tax policy implications )〕 ''The Economist'' has called recent calls in America to restrict companies from relocating abroad by way of merger "misguided" and called for wider tax reform to address what it describes as more fundamental flaws in the American corporate tax system instead. Democratic lawmakers attempted again in September 2014 to propose a tax reform that would focus on slowing the number and rate of corporate inversions via taxing any earnings outside the U.S. as income, until the inversion occurs. Republicans and Democrats have several proposals that could possibly address the issue. An additional consideration surrounding any proposed inversion regulations is whether the regulations would apply retroactively, and further, whether such a retroactive application would be constitutional. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Tax inversion」の詳細全文を読む スポンサード リンク
|