Tax Management International Journal (BNA) | December.13.2014
Inversions have received an enormous amount of attention in the United States in recent years, as scores of companies have relocated to more tax-friendly jurisdictions. However, many non-U.S. companies (particularly in the technology area) may find it preferable to move into the United States to gain access to the U.S. capital markets, thereby creating local law exit tax issues. Set forth is a case study with a fairly typical fact pattern involving a German technology company that is evaluating the consequences of relocating to the United States. We discuss both the German and U.S. tax aspects.
Reproduced with permission from Tax Management International Journal, 43 TMIJ 743, 12/12/2014.
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