https://en.wikipedia.org/wiki/Tax_inversion
The U.S. is unique among developed nations in imposing both a high statutory corporate income tax rate of 35 percent (effective corporate tax rates are lower) and imposing tax on the profits that domestic corporations collect from their subsidiaries abroad. This policy of taxing foreign profits is called a “worldwide” system of taxation, and it contrasts with the “territorial” system employed by most developed countries including the United Kingdom and Canada, which generally tax only profits from domestic activities. The result is that U.S. corporations with subsidiaries in lower-tax jurisdictions face higher taxes on those foreign operations than they would if they were incorporated elsewhere. As Bloomberg View columnist Matt Levine wrote in 2014, “If we’re incorporated in the U.S., we’ll pay 35 percent taxes on our income in the U.S. and Canada and Mexico and Ireland and Bermuda and the Cayman Islands, but if we’re incorporated in Canada, we’ll pay 35 percent on our income in the U.S. but 15 percent in Canada and 30 percent in Mexico and 12.5 percent in Ireland and zero percent in Bermuda and zero percent in the Cayman Islands.”
The Economist explains:
The incentive is simple. America taxes profits no matter where they are earned, at a rate of 39% higher than in any other rich country. When a company becomes foreign through a merger, or inverts, it no longer owes American tax on its foreign profit. It still owes American tax on its American profit.
http://www.bloomberg.com/infographics/2014-09-18/tax-runaways-tracking-inversions.html
April 13, 2015
Corporate Expatriates: See the Data
The roster of corporate expats includes inverted companies and former divisions that they spun off as independent entities, as well as U.S. firms that got a foreign address through a leveraged buyout or other ownership change.
Cyberonics Inc. moving from Texas to England
Wright Medical Group Inc. Tennessee to Netherlands
Steris Corp Ohio to England
Civeo Corp from Texas to Canada
Applied Materials from California to Netherlands
C&J Energy Services Ltd to Bermuda
Mylan Inc. from Pennsylvania to Netherlands
Medtronic Inc. Minnesota to Ireland
Burger King Worldwide Inc. Florida to Canada
Horizon Pharma Inc Illinois to Ireland
Theravance Biopharma from California to Cayman
Paragon Offshore Plc to England
Endo International Plc from Pennsylvania to Ireland
Tower Group International Ltd New York to Bermuda
Liberty Global Plc Colorado to England
Perrigo Co. Plc from Michigan to Ireland
Actavis Plc New Jersey to Ireland
Mallinckrodt Plc to Ireland
Allegion Plc to Ireland
Tronox Ltd. Oklahoma to Australia
Rowan Cos Plc from Texas to England
Aon Plc Illinois to England
Eaton Corp. Plc from Ohio to Ireland
Pentair Ltd to Ireland
Jazz Pharmaceuticals Plc California to Ireland
Stratasys Ltd Minnesota to Israel
D E Master Blenders 1753 NV to Netherlands
Alkermes Plc Massachusetts to Ireland
Trinseo SA to Luxembourg
Valeant Pharmaceuticals Intl Inc California to Canada
Altisource Portfolio Solutions to Luxembourg
Invitel Holdings A/S Washington to Denmark
Ensco Plc Texas to England
Samsonite SA Massachusetts to Luxembourg
Altisource Portfolio Solutions SA to Luxembourg
Convatec Healthcare B S.a.r.l to Luxembourg
James River Group from Virginia to Bermuda
Argo Group International Holdings Ltd Texas to Beruda
Covidien Plc to Ireland
TE Connectivity Ltd. To Switzerland
Freescale Semiconductor to Texas to Bermuda
Travelport Wordwide Ltd to Bermuda
Sensata Technologies Holding Nv to Netherlands
Lazard Ltd New York to Bermuda
Global Indemnity Plc Pennsylvania to Ireland
Michael Kors Ltd New York to Hong Kong
Nabors Industries Ltd Texas to Bermuda
Herbalife Ltd California to Cayman
Noble Corp Plc Texas to England
Weatherford International Ltd Texas to Ireland
Cooper Industries Plc Texas to Ireland
VistaPrint NV Massachusetts to Netherlands
Global Santa Fe Corp Texas to Cayman
Ingersoll-Rand Plc New Jersey to Ireland
Accenture Plc Illinois to Ireland
Foster Wheeler AG New Jersey to Switzerland
Tycom Ltd to Bermuda
APW Ltd to Bermuda
Everest Re Group Ltd New Jersey to Bermuda
Arch Capital Group Ltd Connecticut to Bermuda
Seagate Technology Plc California to Ireland
PXRE Group Ltd New Jersey Bermuda
White Mountains Insurance Group Ltd Vermont to Bermuda
Fruit of the Loom Ltd Kentucky to Cayman
Transocean Ltd Texas to Switzerland
XOMA Ltd California to Bermuda
Gold Reserve Inc Washington to Canada
Chicago Bridge and Iron Co. NV Illinois to Netherlands
Tyco International Plc New Hampshire to Ireland
Loral Space & Communication Ltd. New York to Bermuda
Triton Energy Ltd Texas to Cayman
Helen of Troy Ltd Texas to Bermuda
Core Laboratories NV Texas to Netherlands
Flextronics International Ltd California to Singapore
McDermott International Inc Louisiana to Panama
For me, the off-shore corporate tax structure is the single biggest issue. It is so convoluted not sure it can ever be fixed. Probably convoluted for a reason. ya think?
If this isn’t proof of Laffer, then it’s impossible to prove anything!
Suppose that every day, ten men go out for beer and the bill for all ten comes to $100
If they paid their bill the way we pay our taxes, it would go something like this
The first four men (the poorest) would pay nothing.
The fifth would pay $1.
The sixth would pay $3.
The seventh would pay $7..
The eighth would pay $12.
The ninth would pay $18.
The tenth man (the richest) would pay $59.
So, thats what they decided to do..
The ten men drank in the bar every day and seemed quite happy with the arrangement, until one day, the owner threw them a curve ball. Since you are all such good customers, he said, Im going to reduce the cost of your daily beer by $20. Drinks for the ten men would now cost just $80.
The group still wanted to pay their bill the way we pay our taxes. So the first four men were unaffected. They would still drink for free. But what about the other six men? The paying customers? How could they divide the $20 windfall so that everyone would get his fair share?
They realized that $20 divided by six is $3.33. But if they subtracted that from everybodys share, then the fifth man and the sixth man would each end up being paid to drink his beer.
So, the bar owner suggested that it would be fair to reduce each mans bill by a higher percentage the poorer he was, to follow the principle of the tax system they had been using, and he proceeded to work out the amounts he suggested that each should now pay.
And so the fifth man, like the first four, now paid nothing (100% saving).
The sixth now paid $2 instead of $3 (33% saving).
The seventh now paid $5 instead of $7 (28% saving).
The eighth now paid $9 instead of $12 (25% saving).
The ninth now paid $14 instead of $18 (22% saving).
The tenth now paid $49 instead of $59 (16% saving).
Each of the six was better off than before. And the first four continued to drink for free. But, once outside the bar, the men began to compare their savings.
I only got a dollar out of the $20 saving, declared the sixth man. He pointed to the tenth man,but he got $10!
Yeah, thats right, exclaimed the fifth man. I only saved a dollar too. Its unfair that he got ten times more benefit than me!
Thats true! shouted the seventh man. Why should he get $10 back, when I got only $2? The wealthy get all the breaks!
Wait a minute, yelled the first four men in unison, we didnt get anything at all. This new tax system exploits the poor!
The nine men surrounded the tenth and beat him up.
The next night the tenth man didnt show up for drinks, so the nine sat down and had their beers without him. But when it came time to pay the bill, they discovered something important. They didnt have enough money between all of them for even half of the bill!
And that, boys and girls, journalists and government ministers, is how our tax system works. The people who already pay the highest taxes will naturally get the most benefit from a tax reduction. Tax them too much, attack them for being wealthy, and they just may not show up anymore. In fact, they might start drinking overseas, where the atmosphere is somewhat friendlier.