Overview
On November 4, 2022, Caroline Ngo, will be a panelist at the 75th Annual Federal Tax Conference at the University of Chicago Law School on the topic of “The US’ Anti-Inversion Regime: Is it Time for the Hotel California to Adopt a New Check-out Policy?”
This paper would take a holistic look at the U.S.’s anti-inversion regime and potential for reform. More specifically, the paper would discuss: (i) the history of the anti-inversion regime, (ii) the rationale for the series of rules causing more and more cross-border transactions to be classified as inversions, (iii) the government’s more recent proposals to place further restrictions on such transactions, and (iv) possible reforms to the overall regime to simplify the unwieldy web of rules governing the space while recentering the regime in line with global efforts to combat base erosion and profit shifting consistent through the OECD’s inclusive framework proposals.
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