New Inversions, the 'Joe Frazier Left Hook,' the IRS Notice, and Pfizer
12 Pages Posted: 20 Aug 2014 Last revised: 8 Oct 2014
Date Written: June 23, 2014
Abstract
This article discusses the “New Inversions” many U.S. firms are engaging in, as illustrated by the acquisition by a newly formed Irish holding company of the stock of (1) Endo, a U.S. firm and the real acquirer, and (2) Paladin, a Canadian firm and the real target. The article shows how these transactions are rendering a “Joe Frazier Left Hook” to the Treasury’s “Killer B” regulations even after the issuance by the IRS of Notice 2014-32 on April 25, 2014. The article then explores how “Ali” (a.k.a. Treasury) and the Congress can punch back against these transactions.
Keywords: Inversions, corporate tax, international tax, mergers and acquisitions
JEL Classification: H25
Suggested Citation: Suggested Citation